Privacy Policy

We value your privacy. With this policy, we set out your privacy rights and how we collect, use, disclose, transfer and store your personal data.

Terms we use in this policy

When we say “Freep”, “we”, “our”, or “us”, we mean the entity responsible for processing your personal data.

When we say “public personal data”, we mean personal data published on our application which anyone on the internet and allowed on platform can access, and when we say “private personal data” we mean personal data we don’t publish on our platform.

Third-party websites

Our application contains links to other websites, but that doesn’t mean we endorse those websites. We encourage you to review the privacy policies for these third-party websites because their procedures for collecting, handling and processing personal data might be different to ours.

We’re an open platform

When you write a review, the review and your Freep profile will be visible to anyone who visits our platform. When someone clicks on your profile, they can see your country location and all the reviews you’ve written, including the locations and products you’ve reviewed, and any photos or videos submitted with your reviews. Similarly, if you’re a business user and reply to a review about your company, this will also be visible on our platform. We consider all of this information to be public personal data. You can share as much or as little personal information as you want when creating your Freep profile and username.

Personal data we collect

Personal data is any information that relates to an identifiable individual. When you create a Freep user account, write a review, create an account on behalf of your company, or otherwise use our platform or services, we may collect and process personal data about you. Please see the “Who may access your personal data?” section for more information about who can access it.

We ask you not to share any sensitive personal documents or personal data with us, such as information revealing ethnic origin, religious beliefs, or health information, of yourself or others.

We may collect the following public and private personal data:

Public personal data

User account information: Your name, surname, birthdate (only year), photo, gender (not mandatory) and country location.
Information about reviews and ratings, including:
- Which product name you reviewed.
- The date you wrote your review.
- Your review content and star rating.
- Your product photos.
- Your first and last name.
- Your birthdate year.
- Your Gender (if you specify it).
- Your Country, State and City.
- The link to a platform/web site which sell or share information about the product you reviewed.
Information about finding reviews “useful”: how many people find your review “useful”, and if you click “useful” on someone else’s review.

Private personal data

User account information: Your password and your preferred language.
Contact information: Your name and email address or any other contact details you may provide to us from time to time, whether provided directly to Freep or from social networks.
Information about reviews and ratings, including:
The dates you wrote your review, made any edits the review.
Device and location information: Your IP address, browser settings (the type of browser you use, browser language, time zone), and location.
Usage and profiling information: Your Freep search history, how you've interacted with our platform, or emails we send to you, including time you spend on our site, features or functions you’ve accessed, metadata and event data, marketing emails you’ve opened and links you’ve clicked.
Information about views: How many people read your review.
Number and date of expiry of the documents you submitted.
Preferences information: Selected preferences associated with your account, including specific consents you have given or declined, newsletters or similar email preferences and cookies containing your preferences.
Communication information: Includes communications we receive from you such as review notifications, feedback, help requests and queries via email, and other electronic communication methods, as well as metadata associated with those communications, such as time and date.

How we collect personal data

The personal data that we process is primarily collected directly from you when you provide your details to create an account with us, or your usage and profiling information, meaning your interaction with our platform, services or marketing emails, such as by leaving reviews or posting replies to reviews.

Sometimes we're given information about you from third parties. And we may receive information from third parties for the purposes of fraud and investigation.

We also generate or collect information from your computer or device automatically as you use our services — like your IP address, your location, information about the device and browser you're using to access Freep, or your usage and profiling information, such as your interaction with our platform or marketing emails, or use of our other services.

Who is the controller of your personal data?

A data controller decides how and why your personal data is used and is responsible for ensuring it is handled properly. A data processor acts on a data controller’s instructions to process your data. These definitions come from the General Data Protection Regulation (Regulation (EU) 2016/679).

If you have any questions, or wish to exercise your rights with respect to personal data used to send review invitations to you, you should contact the relevant business or businesses directly, as they are responsible as data controllers.

In respect of all other personal data associated with our platform, such as information you provide when you create an account, leave a review, or submit a reply, Freep, is the data controller.

Why and how we use your personal data

We may use your personal data for the following purposes:

Provide our services to you, including displaying your reviews and giving you access to your user account and our platform, or providing you with access to your account and our website.
Identify you as a registered user when you log into our platform and revisit our platform.
Improve our platform and services and develop product features.
Respond to your questions and provide customer service.
Send you our newsletters.
Personalize your experience on our platform, for example, to tailor content and recommendations based on your interactions with our services.
Engage in various internal business purposes, such as data analysis, audits, fraud detection and content moderation, developing new products and services, improving or modifying our platform and our services, identifying usage trends and insights, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
Exercise or comply with our own legal rights or obligations in connection with legal claims, or for compliance, regulatory and auditing purposes, where necessary. For example, we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body.

If you have a Freep user account, we may also use your personal data to:

Invite you to leave a review of Freep.
Contact you if we’ve identified that your review might breach our policies and, if necessary, ask you to provide documentation to verify your review or experience.
Contact you to tell you how many times your review was read and whether other users find your review useful, or otherwise provide feedback concerning your user account or your review.
Enforce our Terms of Use for Consumers.

We may also use the information in other ways for which we provide specific notice at the time of collection.

We need to process your personal data to:

Perform our contract with you.
Exercise and comply with our own legal rights and obligations and operate an online review platform in compliance with applicable legal acts.
Pursue our legitimate business interests, including but not limited to operating our website and business and providing our services to you. Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose it was collected for. And of course, we'll always ensure our legitimate interests don't unfairly impact on your own rights and freedoms.
Perform a task carried out in the public interest.
Establish, exercise or defend legal claims, where necessary.

In circumstances where you have expressly given your consent for us to process your personal data, for example, when subscribing to our newsletters or accepting certain cookies on your device, you are free to revoke your consent at any time, either by using the functionality provided within the appropriate product feature or by contacting us (see ‘Contact us’ below). However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.

You have the right to object to how we process your personal data, or ask us to restrict the processing. Please see ‘Your rights’ below, for more details.

Who may access your personal data?

Your public personal data on Freep.

We share your public personal data on our platform so that others can read about your experience with a specific business or product. Remember that if you’ve selected to use your real name as your username, this could reveal your identity on our public website.

Your private personal data on Freep.

Some Freep employees will have access to your data to help facilitate everything within the ‘Why and how we use your personal data’ section of this privacy policy. However, Freep operates on principles in which access is limited to those who have a genuine work-related need.

Your personal data shared with independent third-party services, websites and businesses

One of Freep's main goals is to maximize the visibility, availability, and utility of reviews and related content to the world. We therefore permit various independent third parties to access public personal data including, without limitation, usernames, user profile information, review content.

We make public personal data available to such third parties in this way only where they agree to data license terms which implement protections appropriate for the data and the rights of the relevant data subjects. Please see the ‘Your rights’ section below for information about opting out of certain parts of this data sharing.

European Commission-approved method of validating the transfer has been put in place.

Other disclosures

In addition to the above, we share your personal data with the following parties and in the following circumstances:

To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities.
To cooperate with regulatory bodies and government authorities in connection with investigations or case referrals.
To third parties in connection with the enforcement of our Terms of Use for Consumers and Guidelines for Reviewers.
To third parties in order for us to protect our operations or those of our affiliates.
To third parties to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
To third parties in order for us to pursue available remedies, or limit damages that we may sustain.
To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our platform.
To third parties in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).

How long do we store your personal data?

We only keep your data for as long as we need it, or are required to for legal reasons. This depends on why it was collected, and if we have a continuing legal basis to do so (such as to fulfil a contract between us, perform a service you requested, meet legal requirements, or for our legitimate interests). When we no longer have a valid reason to keep your data, we'll either delete it or anonymize it so that it doesn't identify you. We treat data differently depending on what it's used for, but you can delete your personal data or ask us to do that for you at any time (see ‘Your rights’ below).

Personal data you provide, including your reviews, is kept for as long as you have a Freep account, or as needed to provide you with our services. If you delete your Freep account, we retain certain information we are required by law or have compelling legitimate interests to keep. Reasons we might retain some data for longer periods of time include (but are not limited to) security, fraud and platform abuse prevention, complying with legal or regulatory requirements, and defending our legitimate business interests.

How do we keep your personal data secure?

Keeping your personal data secure is our highest priority. We use various organizational, technical and administrative measures to protect your personal data within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a completely secure environment, we can’t ensure or warrant the security of the information you transmit to us. Emails sent via the platform may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.

We’re always working to improve our security practices and policies, and we will update this information as these practices evolve over time.

Do we use cookies?

Your rights

If we hold personal data about you, you have rights in relation to this data as set out below.

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law, or have an overriding legitimate interest, to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.

Access and download your personal data:

You have the right to obtain confirmation as to whether or not Freep is processing personal data about you, and, where it is, access that personal data, as well as other information about the data.

Correction and deletion of your personal data

If any of the personal data we have about you is incorrect or misleading, if your personal data changes or if you no longer wish to appear on the platform, you can correct, edit or delete the information yourself via your Freep user account.

See ‘How long do we store your personal data?’ for more information on deleting your data.

Right to object

We may share your public personal data with certain partners (see “Your personal data shared with independent third-party services, websites and businesses”).

Other rights

In addition to the rights set out above concerning your personal data, you also have the right to object to the processing of your personal data, and the right to have the processing of your personal data restricted (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, for example the processing of your personal data for direct marketing purposes).

Where we have asked for your consent, you may withdraw your consent at any time. You may withdraw your consent either by using the functionality provided within the appropriate product feature or by contacting us (see ‘Contact us’ below). If you ask to withdraw your consent to Freep processing your data, this will not affect any processing which has already taken place at that time.

Please note that the above rights are not absolute and might be limited. For example, we may not comply with your request if fulfilling it would reveal personal data about another person, or if you ask us to delete information which we are required by law, or have compelling legitimate interests, to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.

U.S. privacy rights

This section provides additional details about the personal data we collect from consumers in the U.S. who are afforded rights under applicable state data protection and privacy laws. These laws include, but are not limited to, the California Consumer Privacy Act, the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Delaware Personal Data Privacy Act, the Florida Digital Bill of Rights, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Jersey Data Protection Act, the New Hampshire Act Relative to the Expectation of Privacy, the Oregon Consumer Data Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, and any other state or local laws applicable to U.S. residents’ data. These laws may be amended, repealed, or replaced over time (the “U.S. Privacy Laws”).

When we say personal data in this section, we mean “personal data” or “personal information”, as defined in the applicable U.S. Privacy Laws.

For more details about the personal data we collect, please see ‘Personal data we collect’ above. We collect this data for the purposes described in ‘Why and how we use your personal data’ above. We share this data with the categories of third parties described in ‘Who may access your personal data’ above.

Under the U.S. Privacy Laws you have a number of rights over the personal data we hold about you and we are committed to exercising those rights, where they apply. For more details about your rights in relation to our processing of your personal data, please see ‘Your rights’ above.

In accordance with the U.S Privacy Laws’ requirements, we will not discriminate against you for exercising any of your rights. You may make a request pursuant to your rights by contacting us using the contact details set out below. We will verify your request using the information associated with your account, including the email address. You may designate an authorized agent to exercise these rights on your behalf.

Freep may transfer your personal data to third parties who enter into licensing agreements with us and to our partners for things like displaying personalized ads to you or to deliver improvements to our service. Under U.S Privacy Laws you may request to opt out of the sale or sharing of your personal data to third parties. To manage your privacy preferences and opt out of the sale or sharing of your personal data, please contact us using the contact details set out below.

Freep will never sell your private personal data for profit, however, to comply with the U.S. Privacy Laws where we transfer it to our partners for activities including, but not limited to, displaying personalized ads to you, licensing our data (see “Your personal data shared with independent third-party services, websites and businesses”) or to deliver improvements to our service, we allow you to opt out. We only engage in this kind of data transfer where we believe it benefits you by providing you with a better experience, quality of service or to deliver content that you may be interested in.

Children’s information

Our platform is not directed to children under the age of 18, and we do not knowingly collect personal data from such children. If you become aware that a child under the age of 18 has provided us with their personal data, please contact us using the contact information provided below.

Changes to this policy

We may change this policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed.

If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through our platform. Your continued use of our platform or services after we publish or send a notice about the changes to the policy will mean that you accept and agree to the updated policy.

We aim to make this information as clear and transparent as possible. But if you still have questions about how we process your personal data, or would like to exercise your rights under our policy, you're welcome to contact our Data Protection Officer at Freep.info@gmail.com.