Privacy And Data Protection Policy
Please, read the following information carefully to understand the views and practices of FREE2EX (hereinafter – we, FREE2EX) regarding your personal data and how we treat it. By using our website (www.free2ex.com) (hereinafter – Website) and/or our application in AppStore and/or Google Play Store (hereinafter – Application), you are agreeing to be bound by this Policy.
We know that you are concerned with how we deal with your personal data. This Policy sets out our current policies and demonstrates our commitment to your privacy. This Policy may be changed at any time in future. Revisitation, continued access to or use of the Website and/or Application shall mean that you agree with the changes.
Purpose of the personal data processing
We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations. We recognize the importance of correct and lawful treatment of personal data as it helps to maintain our company's confidence, to ensure efficient and successful outcomes of using such data.
The purpose of processing the personal data is the conclusion, execution and termination of agreements between FREE2EX and you, providing you access to services, information and / or materials contained on the FREE2EX Website and/or Application, providing you with information about promotions and offers, other information and materials of FREE2EX that may be relevant to you, compliance with the requirements of the current legislation governing the activities of FREE2EX, in accordance with which FREE2EX is obliged to collect and store information about you for a certain period.
We only use your personal data as appropriate to provide you with a high quality of service and security. For example, we may use personal data collected from you to verify your identity and contact information. This information helps us to improve our services and inform you about new products, services or promotions that may be of interest to you.
Personal data may consist of data kept on paper, computer or other electronic media, all of which is protected under the applicable personal data protection laws.
Principles of personal data processing
All personal data is:
• fairly and lawfully processed;
• processed for a specified purpose;
• adequate, relevant and not excessive;
• not kept for longer than necessary;
• processed in accordance with the individual's (data subject's) rights;
• not transferred to other countries without adequate protection.
Personal data we collect
We may collect and process the following personal data of you:
• information that you provide by filling in forms on our Website and/or Application, in emails, by calls;
• up-to-date data about yourself, if you register your personal details for our service;
• details of your visits to our Website and/or Application (including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access).
The types of personal data that we may process, for instance, include information about current, past and prospective clients and customers, Website and/or Application visitors, etc. with whom we deal. This information includes information required to communicate with you, including but not limited to your name, mailing address, telephone number, email address, birth date and your location information.
We may also ask you for information when you report a problem with the Website and/or Application. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You have a choice when you are asked to provide personal data. You may agree or refuse to provide us with your personal data. You also entitled to make FREE2EX erase your personal data, cease further dissemination of your personal data and potentially have third parties halt processing of the data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, if you choose not to provide us with your personal data necessary for our services provision or to withdraw the data that is still relevant to original purposes of processing, you may not be able to use our service.
You may at any time withdraw your consent to the processing of personal data by sending a notification to FREE2EX by e-mail at firstname.lastname@example.org marked "Withdrawal of consent to the processing of personal data".
The personal data we collect depends on the context of your interactions with FREE2EX, the choices you make, including your privacy settings, and the service you use.
We may share information about visitors of the Website and/or Application with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pages you visit. The information collected by the advertising company through the use of these pixel tags is not personally identifiable.
Reasons we share your personal data
We share your personal data with your consent or as necessary to provide any service you have requested. We also share your personal data with FREE2EX affiliates and subsidiaries, with vendors and service providers providing software, IT and other services in order to provide our services to you. We share your personal data with third person and authorities if this is required by law, in respond to legal process, to protect our clients, to maintain the security of our services and to protect the rights or property of FREE2EX.
To improve our user experience, we may transfer the personal data of our current and (or) potential customers solely for the purpose of its processing and our services provision.
Our affiliates and partners
We may share information with affiliates and partners if the information is required to provide the product or service you have requested, or to provide you with the opportunity to participate in the products or services our affiliates offer. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our customers. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to understand better the offers that are most relevant and useful to you. The use of your personal data is limited to the purposes identified in our relationship with the partner or affiliate.
Non-affiliated third parties
We do not sell, license, lease or otherwise disclose your personal data to any third party for any reason, except as described below.
We reserve the right to disclose your personal data to third parties when required to do so by law to regulatory, law enforcement or other government authorities. We may also disclose your personal data as necessary to credit reporting or collection agencies. We may also disclose your personal data to non-affiliated third parties if it is necessary to protect the FREE2EX rights or property.
To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with customer's information from our database to help us to analyze and identify customer's needs and notify customers of product and service offerings. Use of the shared information is strictly limited to the performance of the task we request and for no other purpose. All third parties with which we share personal data are required to protect personal data in a manner similar to the way we protect personal data. We use a variety of legal mechanisms, including contracts, to help ensure your rights and protections.
Cross-border transfer of personal data
We carry out cross-border transfer of personal data only to the territory of a state, which provides reliable protection of the rights of users.
Cross-border transfer of personal data to the territory of countries that do not meet the above requirements can be carried out only if you are informed about the risks arising from the lack of an adequate level of protection of Personal data in such countries, the receipt of personal data on the basis of an agreement concluded (concluded) with you, in order to perform the actions established by this agreement; obtaining personal data by any person by sending a request in the cases and in the manner prescribed by law; transfer of data when such is necessary to protect the life, health or other vital interests of the subject of personal data or other persons, if obtaining the consent of you is impossible; obtaining the appropriate permission from the authorized body for the protection of the rights of subjects of personal data.
Restriction of responsibility
Access to your personal data
All individuals who are the subject of personal data held by us are entitled to:
- ask what information we hold about them and why;
- ask how to gain access to it;
- be informed how to keep it up to date;
- have inaccurate personal data corrected or removed;
- to receive the personal data concerning them, which they have previously provided;
- prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;
- require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;
- be informed what we are doing to comply with our obligations under the applicable data protection laws.
If you cannot access certain information and personal data collected by FREE2EX, you can always contact us by using our contact form. We will respond to requests to access or delete your personal data within 30 days.
In addition to a contact form, you may request at any time to receive information regarding the processing of personal data by sending a notification to FREE2EX by e-mail to email@example.com marked "Receiving information regarding the processing of personal data". In case of detection of inaccuracies in personal data, you can update them yourself by sending a notification "Change of personal data" to FREE2EX.
You may request at any time to receive information about the provision of personal data to third parties by sending a notification to FREE2EX by e-mail to firstname.lastname@example.org marked "Obtaining information about the provision of personal data to third parties".
You may request at any time to stop processing personal data and (or) delete information by sending a notification to FREE2EX by e-mail to email@example.com marked "Stop processing personal data and (or) delete information."
Security of your personal data
We maintain strict security standards and procedures with a view to preventing unauthorized access to your personal data by anyone, including our staff. We use leading technologies to secure your personal data: hardware and software facilities. The hardware protection includes Cisco security products. The software protection tools include strict control mechanisms as follows: SSL 3, TLS 1.2 with keys equal or larger than 2048-bit. All FREE2EX members, all our staff and third parties whenever we hire them to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.
Where your personal data is stored and processed
We transfer your personal data from the European Economic Area to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protection of your personal data.
Retention of your personal data
FREE2EX retains your personal data for as long as necessary to provide the services, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:
• the period of your personal data processing needed to provide the services. This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. It is a general rule that establishes the baseline for most data retention periods.
• the personal data subject's consent for a longer retention period. If so, we shall retain your personal data in accordance with the consent.
• FREE2EX is subject to a legal, contractual, or similar obligation to retain your personal data. Mandatory personal data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal data that must be retained for the purposes of litigation.
If you have any privacy concern, complaint or a question, please, contact us via our contact form, phone no.: +375 17 319-55-83 or send an email to firstname.lastname@example.org. We respond to questions and concerns within 30 days.
Unless otherwise stated, Pixel Internet LLC is a data controller for personal data we collect through the services subject to this statement.