How is Your Personal Data Collected?

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

1. Information You give us: You may give us information about You by filling in forms on our sites, applications, software, programs, platforms, or tools (collectively, our “Sites”), or by corresponding with us by phone, e-mail or otherwise. This includes information You provide when You register to use our Sites, subscribe to our service, search for a product or service, complete any forms, surveys or statements, place an order on our Sites and when You report a problem with our Sites. The information You give us may include (without limitation): Your name or company name, company number, VAT number, social security number, address, e-mail address and phone number, financial and payment card information and personal descriptions, photographs and copies of identity documents (such as passports).
2. Information we collect about You: With regard to each of Your visits to our Sites we may automatically collect the following information:

• technical information, including (without limitation) the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Sites (including date and time); products or services You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.We collect this personal data by using cookies, beacons, and other similar technologies. Please see our Cookie Policy for further details.

• Information we receive from other sources: We may receive information about You if You use any of the other websites we operate or the other services we provide. In this case we will have informed You when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, without limitation, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about You from them.

How We Use Your 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:

• Where we need to perform the contract we are about to enter into or have entered into with You.
• 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.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not wholly rely on consent as a legal basis for processing Your personal data other than in relation to sharing third parties Your personal data for direct marketing communications, which may be sent via email or text message. You have the right to withdraw consent to marketing at any time by opting out of the email or text message or by contacting us using the contact information provided below.

Purposes For Which We Will Use Your Personal Data

We use information held about You in the following ways:

1. Information You give to us: We will use this information:
   1. to carry out our obligations arising from any contracts entered into between You and us and to provide You with the information, products and services that You request from us;
   2. to provide You with information about other goods and services we offer that are similar to, or complementary to, those that You have already purchased or inquired about or may have interest in;
   3. to provide You, or permit selected third parties to provide You, with information about goods or services we feel may interest You. If You are an existing customer, we will only contact You by electronic means (e-mail or SMS) and by phone with information about goods and services similar to, or complementary to, those which were the subject of a previous sale or negotiations of a sale to You. If You are a new customer, and where we permit selected third parties to use Your data, we (or they) will contact You by electronic means or by phone only if You have consented where required by law, or if You have not unsubscribed from electronic communications. If You do not want us to contact You for marketing purposes, please update Your preferences by visiting our email communications preference center or select the applicable unsubscribe feature;
   4. to notify You about changes to our service;
   5. to ensure that content from our Sites is presented in the most effective manner for You and for Your computer.
2. Information we collect about You: We will use this information:
   1. to improve our services, administer our Sites, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
   2. to improve our Sites to ensure that content is presented in the most effective manner for You and for Your computer;
   3. to allow You to participate in interactive features of our service, when You choose to do so;
   4. as part of our efforts to keep our Sites safe and secure;
   5. to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
   6. to make suggestions and recommendations to You and other users of our Sites about goods or services that may interest You or them.
3. Information we receive from other sources: We may combine this information with information You give to us and information we collect about You. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Note that we may process Your personal data for more than one lawful ground depending on the specific purpose for which we are using Your data. Please contact us if You need details about the specific legal ground we are relying on to process Your personal data.

Marketing

Cookies

Our website uses cookies to distinguish You from other users of our website. This helps us to provide You with a good experience when You browse our website and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Change of Purpose

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.

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.

Disclosures of Your Personal Data

We may share Your personal information with any member of the Freeman Group.

We may share Your information with selected third parties including, but not limited to:

1. Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or You;
2. Advertisers and advertising networks that require the data to select and serve relevant advertisements to You and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate anonymized information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from You to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
3. Analytics and search engine providers that assist us in the improvement and optimization of our Sites.

We may disclose Your personal information to third parties:

1. In the event that we sell or buy any business or assets, in which case we may disclose Your personal data to the prospective seller or buyer of such business or assets;
2. If Freeman or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
3. If we are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use, Cookie Policy and other agreements; or to protect the rights, property, or safety of Freeman, the Freeman Group and our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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. To the extent a third party is engaged by Freeman to process Your personal data in accordance with our instructions, Freeman remains responsible and liable to You if a third party processes Your personal data, unless Freeman proves that it is not responsible for the event giving rise to the damage.

International Transfers

We share Your personal data within the Freeman Group. This may involve transferring Your data outside the US or to external third parties based outside the US.

Data Security

All information You provide to us is stored on our secure servers. Personal data is transmitted to other websites through the use of Transport Layer Security (TLS) encrypted protection. Where we have given You (or where You have chosen) a password which enables You to access certain parts of our Site, You are responsible for keeping this password confidential. You are prohibited from sharing Your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to our Site; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorized access.

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.

Data Retention

How Long Will You Use My Personal Data For?

We will only retain Your personal data as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity 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 the applicable legal requirements.

Where We Store Your Personal Data

The data that we collect from You may be transferred to, and stored at, a destination in the US, where many of our central databases operate. Freeman is a company that operates globally so personal data may also be processed by staff operating outside the US who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of Your order, the processing of Your payment details, and the provision of support services. If You are located outside of the US, You use the Sites at Your own risk. By using the Sites and the services related thereto, You acknowledge that the data protection and other laws of other countries may provide a less comprehensive standard of protection than those in Your country.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Your Legal Rights

You have the following rights under data protection laws in relation to Your personal data.

The right to:

Request access to Your personal data (commonly known as a “data subject access request”). This enables You to receive a copy of the personal data we hold about You and to check that we are lawfully processing it.

Request 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.

Request 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.

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.

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: (a) if You want us to establish the data’s accuracy; (b) where our use of the data is unlawful but You do not want us to erase it; (c) 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; or (d) You have objected to our use of Your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

If You wish to exercise any of the rights set out above, please contact us at [email protected].

No Fee Usually Required

You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with Your request in these circumstances.

What We May Need From You

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.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Applicable Law

This Privacy Policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by the laws of the State of Texas. We both agree to the exclusive jurisdiction of the courts of Dallas County, Texas, USA.

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to the privacy team at one of the following methods set out below.

Our full details are:

Freeman
Address: P.O. Box 660613
Dallas, TX 75266-0613
Email: [email protected]
Phone: 214-445-1000
Toll-Free: 1-800-423-8416
Web Form: https://dev.freeman.com/contact

California’s “Shine the Light” Law

If You are a California resident and wish to review or change the personal data of Yours which Freeman possesses, please contact us by one of the ways listed above in the Contact section.

Transfers Of Personal Data Outside The European Union

As described above, sometimes we must transfer Your data, including personal data, to staff operating outside the US, including the European Union (“EU”) and the greater European Economic Area (“EEA”), who work for us or for one of our suppliers. The relevant data is transferred in order to, among other purposes, fulfill Your order, process Your payment details, or to provide services, including marketing services. The governing body of the European Union, the European Commission, has ruled that certain countries outside of the EEA adequately protect personal data and some do not. In order to transfer data from the EEA to other countries, such as the United States, that in the European Commission’s view do not adequately protect personal data, we comply with legal frameworks that establish an equivalent level of protection with EU law. The European Commission’s Standard Contractual Clauses (“SCC”) are such a framework permitting the transfer of personal data outside the EEA and we incorporate these into our Data Processing agreements that we append to our contracts. By accessing and using our sites and providing us with Your information You acknowledge and agree that any such data that may be sent to the EEA will be processed and returned from the EEA to us through the SCC.

Executive Summary of Freeman’s US & EU Data Protection

Freeman strives to continuously improve our data protection efforts while keeping applicable data privacy laws in mind, including CCPA and GDPR. See our efforts to date.