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FreeAgent CRM Privacy Policy

Cookies

As you navigate our website and our CRM platform (“Platform”), FreeAgent may collect information through the use of commonly used information-gathering tools, such as cookies and similar technologies.

What are cookies?

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”). Except for essential cookies, all first-party cookies will expire after 365 days or less.

Cookies are used to store and receive identifiers and other information on computers, phones, and other devices such as your browser type, IP address, device type and ID, language, and operating system. Cookies are also used to better understand your interest in our website or Platform. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this policy, we refer to all of these technologies as “cookies.” This policy explains how we use cookies, as well as your rights to control our use of them.

Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

Through use of cookies, we may collect:

Browser type;
IP Address;
Mobile application;
Device type or ID: Device user ID;
Browser language;
Operating system;
Referring site (site you visited before coming to our website);
Date and time of visit;
URL of pages visited; and
Other browsing behavior, such as white papers downloaded.

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).

We use cookies to authenticate your use of the Platform. For example, if you’re signed in to our Platform, cookies help us show you the right information and personalize your experience. We use cookies to enable and support our security features, and to help us detect malicious activity. We also use cookies to manage your preferences and provide you with customized content. For example, cookies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our website more easily. We also use cookies to understand and improve our products, features, and services.

We use cookies for marketing purposes. We partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies to gather information about your activities on other sites in order to measure the effectiveness of our advertising or to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by deleting the cookie information from your browser. Most browsers allow you to remove and block cookies and you should visit your browser’s help menu for more information. Please note this does not opt you out of being served generic, untargeted ads.

Please note that if you choose to erase or block cookies, you will need to re-enter your user ID and password to access certain parts of our website. In addition, if you block cookies, you may not be able to use certain features of our Platform or take full advantage of our services.

We may link information obtained through cookies to personal data to provide better service to you and to improve our product and services offerings. For more information about how we process your personal information, please consult our Privacy Policy.

Please note that many Internet browsers allow users to send a “Do Not Track” signal to websites they visit. Currently, there is no consensus on the meaning of “Do Not Track” or similar signals, and our website and services have no mechanism to respond to such a signal.

For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.

Other tracking technologies

We may also use mobile device identifiers and the other technologies identified in Section 5 of our Privacy Policy for the purposes articulated in our Privacy Policy, for example to recognize your device when you use our Platform.

Controlling Cookies

Visitors may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our service may not function correctly.

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:

●     networkadvertising.org

●     optout.aboutads.info

●     youradchoices.com

●     youronlinechoices.eu

On a mobile device, you may also be to adjust your settings to limit ad tracking.

You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

Google Analytics

On our website and for our online offerings we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

Google Analytics uses cookies, small text files that are stored on your computer and which enable an analysis of the use of our internet offerings. The information about the use of our website (including the IP address of the user) which is generated by the cookie will be transferred to a Google server in the USA and stored there.

Google will use this information to analyze the use of the website, to compile reports about the website activities for the website’s operator and to provide further services which are connected to the use of this website and of the internet. If legally required, or if third parties process this data on behalf of Google, Google may also forward this information to third parties. With the statistics that we obtain, we can improve our offer and make it more interesting for you, the user. The legal basis for the use of Google Analytics is Art. 6(1) sent. 1 (f) GDPR.

Our website also uses the Google Analytics reports function on demographic attributes. In this respect, data from interest-based advertising from Google as well as visitor data from third party service providers (e.g. age, gender and interests) are used. This data cannot be associated with a specific person. The function can be deactivated at any time using the display settings. With the statistics that we obtain, we can improve our offer and make it more interesting for you, the user. The legal basis for the use of Google Analytics is Art. 6(1) sent. 1 (f) GDPR.

You can prevent the storage of the cookies by setting your browser software accordingly; please note, however, that in this case, you may not be able to use all the functions of our website to their full extent. You can also prevent the collection of the data generated by the cookie relating to the use of our website (including the IP address) at Google and/or the processing of this data by Google by downloading and installing the browser plug-in which is available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

You can find information from Google about the conditions of use at: https://www.google.com/analytics/terms/de.html, the data protection overview at: http://www.google.com/intl/de/Analytics/terms/learn/privacy.html, the privacy policy at: http://www.google.com/intl/de/policies/privacy.

Google has agreed to comply with the EU-US Privacy Shield, https://www.privacy-shield.gov/EU-US-Framework.

Facebook Remarketing

The Free Agent CRM website uses the “Custom Audiences” remarketing function of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). With this function, the provider is able to address visitors to the website with targeted advertising by placing personalized, interest-based Facebook advertisements for visitors to the website if they visit the social network Facebook. The legal basis for the use of Facebook Remarketing is Art. 6(1) sent. 1 (f) GDPR. To carry out this function, the Remarketing Tag from Facebook is implemented on the website of the provider.

When you visit our website, these tags establish a direct connection to the Facebook servers. In this way, the Facebook server is informed which of our web pages you have visited. Facebook will assign this information to your personal Facebook account. Further information on the collection and use of the data by Facebook as well as your related rights and options for the protection of your private sphere are provided in the data protection information of Facebook at https://www.facebook.com/about/privacy/ . If you do not wish Facebook to assign the data collected directly to your Facebook account, you can deactivate the “Custom Audiences” remarketing function in your Facebook settings. To do this, you have to be logged into Facebook.

YouTube Video Embed

Videos from the company YouTube, YouTube LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, a company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA are integrated on this website, which are saved at http://www.youtube.com and can be played back directly from our website.

All of the videos have been integrated in the “enhanced data protection mode”, which means that no data about you as a user will be transferred to YouTube unless you play the videos. The data stated in the following paragraph will only be transferred if you play the videos. Free Agent CRM has no influence over this transfer of data.

YouTube receives a notification when you access a sub-page on our website that features a YouTube video. Some data collected through use of our website, as described in our Privacy Policy, may also be transferred. This will take place regardless of whether YouTube provides a user account into which you are logged in or if no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not want the data to be assigned to your YouTube profile, you must log out before playing a video. YouTube will store your data as user profiles and use it for the purposes of advertising, market research and/or the needs-based configuration of its website. In particular, this evaluation takes place (including for users who are not logged in) for the provision of needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles; if you intend to exercise this right, it is necessary for you to contact YouTube.

YouTube is used in the interests of ensuring an appealing presentation of our online offerings. The legal basis is Art. 6(1) sent. 1 (f) GDPR.

For further information on the purpose and scope of the data collection and its processing by YouTube, please refer to the privacy policy of YouTube. There, you will also find further information about your rights and settings options for the protection of your private sphere: http://www.google.com/intl/de/policies/privacy. Google processes your personal data in the USA, and has agreed to comply with the EU-US-Privacy-Shield, https://www.privacy-shield.gov/EU-US-Framework.

More Information

More detail on how businesses use cookies is available at www.allaboutcookies.org.

If you have any queries regarding this Cookie Policy please email support@freeagentcrm.com

1. Introduction
2. Information we collect
3. How we use the information we collect
4. How we share the information we collect
5. Cookies and other tracking technologies
6. Information collected by third parties
7. Email opt-out
8. Credit card processing
9. Security
10. Children and COPPA compliance
11. Business transitions
12. California users consumer rights
13. Users located outside of the United States
14. EU users’ rights under the GDPR
15. Data retention
16. Cooperation with law enforcement; fraud protection
17. Changes to this Privacy Policy
18. Who we are

1. Purpose of this Privacy Policy

Please read the following policy to understand how your personal information will be treated as you make full use of our Website. When we talk about our Website or our Service, we are referring to freeagentcrm.com, any corresponding mobile application and any services provided by us through such website and/or application. When we talk about FreeAgent, “we”, ‘’our’’ or ‘’us’’ in this policy, we are referring to Free Agent Network, Inc., the company that provides the Website and Service. If you have any questions, concerns or complaints related to this Privacy Policy or our processing of your personal information, please email us here: support@freeagentcrm.com. This email address is monitored on a regular basis and we aim to respond to your query as soon as possible.

The Privacy Policy has three main purposes:

  1. Explain the way we use information that you share with us in order give you a great experience with our Service;
  2. Ensure that you understand what information we collect with your permission, what we do with it and with whom we share it; and
  3. Explain your rights under applicable law.

All the information we collect is related to providing our Website or Service. By agreeing to our Privacy Policy, you give us the right to collect your information as detailed in this Privacy Policy and use it for the purposes described in this Privacy Policy. If you don’t agree with the terms of this Privacy Policy, then please don’t use the Website or Service.

2. Information we collect

The information we collect can be divided into the following broad categories:

  • Technical Data includes internet protocol (IP) address, your login data, device type, device version, browser type and version, browser plug-ins types, time zone setting and location, traffic data, search criteria, weblogs and other communications data, operating system and platform and other technology on the devices you use to access the Website.
  • Usage Data includes information about how you use our Website or Service, such as the particular pages you interact with, how often you visit, how long you’re on the Website, surveys, your usage of the Service and the emails you interact with.
  • Verification Data includes proof of identity and proof of address as further detailed in our Subject Access Request Form.
  • Financial Data includes payment card details you provide, including expiration date. It also includes details about your payment history and services you have purchased from us.
  • Identity Data includes full name, date of birth and/or gender. It also includes billing address, telephone number, email address, username, password.
  • Image Data includes photographs and videos of you that you provide.
  • Email Account Data includes email messages, contacts and calendar

More specifically, we may collect and store the following information relating to you:

2.1 Anonymous data

When you visit our Website or use our Service, we collect some basic information that does not identify individual users. This includes which pages are visited and any feedback from our visitors. We then aggregate this information with other pieces of information to improve our Service and make your experience on the Website as valuable and efficient as possible. We may also collect and accumulate anonymous data that will help us understand and analyze the online experience of our users. For instance, we may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement.

2.2 Direct Interactions
We collect information from you when you voluntarily submit information directly to us or via our Website. For members, this refers to personal data you provide when, for example, you create an account, complete a profile, or by corresponding with us via phone, email or live chat. This personal information may include name, age, address, phone and email, as necessary to set up your account.  If you integrate a third-party application (e.g., Gmail) with our Service, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and to access your email messages (but only those for which you have given your specific consent), address book, contacts lists, and calendar information. FreeAgent typically keeps that data for three (3) years, after which it is deleted permanently.

You may decide to provide us with another person’s contact information so that person may be invited to join our Service or so that we may facilitate your communication with other people through the Service. You may also provide us with another person’s contact information for purposes of delivering information through third-party applications (e.g. Gmail). We store the information that you provide so that the respondents may be added to your network, and also to send reminders of the invitations.  All invitees are provided with the option not to receive further invitations from us.

In addition to the information we may collect upon your initial registration, we may ask you for personal information at other times.  We will not share that information in a manner that identifies you as an individual with any other entity unless we have your permission.

2.3 Information submitted by you for inclusion on the Website

Information, pictures and media files you may upload to the Website will be posted on the Website, subject to our Terms of Use and accessible by other users of the Service; we have no control over how such visitors will use such submissions.   Please remember that if you post any of your personal information in public areas of the Website, such as in online forums or chat rooms, such information may be collected and used by others over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Website. You should take care to not use personal information in your screen name or other information that might be publicly available to other users.

2.4 Tracking technologies

We use “cookies” and similar tracking technologies (as described in Section 5 below and in our Cookie Policy) to track your activities on our Website, and may also receive data about you if you visit other websites employing our cookies. When we send you emails that include a link to the Website, that link may contain an alphanumeric identifier that allows us to identify the person to whom we sent the message so that we can personalize our content for that individual.

  • Automated technologies or interactions

As you interact with our Website or use our Service, we may automatically collect technical and usage data about your device, browsing actions and patterns. For example, we collect information which may include your IP address, browser type, your location, language preferences, device information and access times. While an IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. We also collect IP addresses for system administration and to report aggregate information to any sponsors.  We may also receive information from our web logs, which automatically record anything a web server sees, which may include email addresses you enter into a form or pages viewed by a user at a particular IP address. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using our Service.

2.6 Payment data

If you purchase a subscription to our Service or make other purchases through the Website, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to process your purchase. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.

2.7 Promotions & surveys

From time to time, we may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers, and/or surveys (“Special Promotions”) through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and our Terms of Use. If the provisions of the Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or  our Terms of Use, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy or in the Special Promotion.

 2.8 Information received from our service providers and partners

We may also receive information about you from our service providers and partners, which we use to personalize our Service, to measure ad quality and responses to ads, to display ads that are more likely to be relevant to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you.

3. How we use the information we collect

We have set out below, in a table format, a description of all the ways we process your personal data, and the legal basis we rely on to do so.

Purpose/ActivityType of DataLegal Basis
To allow you to visit the Website or use the ServiceTechnical Data
Usage Data
Consent
To allow you to integrate an email account with our Service; if an email account is “paired”, we will be able to read, compose and send emails from that account; to see, edit and download contacts from that account’s contact list; and to see, edit and share meetings from that account’s calendar.Identity Data
Email Account Data
Consent
To allow you to create an accountIdentity Data
Usage Data
Image Data
Consent
To register you as a paid member and process renewal of your membershipFinancial Data
Identity Data
Consent
To manage our relationship with you. For example general enquiries such as how the Website works, complaints and payment queriesAny data you choose to share with us or request us to viewConsent
To administer and protect the Website (including troubleshooting, fraud prevention, spam prevention, security incident prevention and correction, data analysis, testing, system maintenance, support, reporting and hosting of data), operate the Website (including notifying you of any changes), optimize your user experience, and send you service and support messages such as updates, patches and security alertsFinancial Data
Identity Data
Technical Data
Usage Data
Consent
To send you promotional messages, marketing, advertising and other such information we think may be of interest to you, either directly or through one of our partners; you may opt out from receiving certain messages, as described in Section 7Financial Data
Identity Data
Technical Data
Usage Data
Consent
To enable you to partake in a prize draw, competition, referral scheme, rewards program, promotional activities, events, complete a survey or invite you to participate in Website testingFinancial Data
Identity Data
Technical Data

a.

Consent
To analyze your use of the Service and deliver relevant website content and third-party advertisements, for example by providing customized, personalized, or localized content, recommendations, features, and advertising.Usage DataConsent
To enforce this Privacy Policy, our Terms of Use, and any other terms that you have agreed to, including to protect the rights, property, or safety of our users, or any other person, or the copyright-protected content of the WebsiteIdentity Data
Usage Data
Technical Data

a.

For purposes of legitimate interests
To maintain and retain records in connection with actual and potential legal claims and regulatory investigations; and for governance & compliance purposesFinancial Data
Identity Data
Usage Data
Technical Data
Necessary for the compliance with a legal obligation to which we are subject

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.

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.

4. How we share the information we collect 

This section describes how the information collected or generated through your use of the Service may be shared by us with third parties. Email Account Data is not shared with any third parties. You can choose to share your Email Account Data within the Service and to customize access through the Service’s Access Control Levels.

4.1 Marketing and advertising

We may share information with advertising partners in order to send you promotional communications about our Website or to show you more tailored content. We may also share aggregate user information in a non-personally identifiable manner with third parties in order to present to users more targeted products and services.  We do not provide any personally identifiable information to third-party advertising companies.

4.2 Service providers

We may from time to time share your information with third-party service providers to perform functions and process user data and help provide our Website or Service, consistent with this Privacy Policy. For example, we work with analytics providers to help us understand the use of our Service. Where a third party processes user data on our behalf, it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law; we only permit them to process your personal data for specified purposes and in accordance with our instructions. Where a third party processes user data on its own behalf, its processing is subject to its own Privacy Policy and applicable law.

To provide you with the best experience on our Website, we use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymized.

For your information, click here to view some examples of how third parties process your personal data.

4.3 Promotions and surveys

When one or more of our business partners co-sponsor a service, promotion, contest/sweepstakes, or survey, we may share some or all of the information collected in connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of that information. If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion, contest/sweepstakes, or survey.

5. Cookies and other tracking technologies

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

There are also technologies such as mobile device identifiers and SDK integrations to help companies recognize your device when you return to an app or otherwise use a service.

Our policy regarding cookies can be found here.

6. Information collected by third parties

Some entities that have links on our Website, such as advertisers, may collect personally identifying information about you when you access or utilize those links.  We do not control the collection or use of such information, and the practices of those entities are not covered by this Privacy Policy. For instance, if you click on an advertisement on our Website, you may be taken away to an entirely different site.  Links can be from advertisers, content providers and/or partners who may use our logo and/or style as a result of a co-branding agreement yet they may still not follow the same policies as this Privacy Policy with respect to collection of your personal information.

Please read these third parties’ privacy policies to find out how they collect and process your personal information.

7. Email Opt-out 

Users who no longer wish to receive email updates or other notifications may opt out of receiving these communications by following the instructions contained in the applicable email or by logging in and changing their account settings.  Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your information.

8. Credit Card Processing

Payments are handled by a third-party processor that receives credit card numbers and other personally identifying information only to verify credit card accounts and process transactions.  

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORIZE US TO USE AND SHARE WITH CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO US, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROCESSING OF YOUR PURCHASE(S) AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO US AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH US.

9. Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorized way. With regard to “paired” email accounts, email correspondence and meeting information are encrypted at rest and in transit through the Service. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorized parties will not be able to defeat those measures: unauthorized entry or use, hardware or software failure, and other factors may compromise the security of our user information at any time.

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.

10. Children and COPPA compliance

Our site is not directed to children under the age of 13 and we do not knowingly collect data relating to anyone under the age of 18. We have designed this privacy policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”). We will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to third parties. If a parent believes that his or her child has submitted personal information to us, he or she can contact us via e-mail or postal mail as listed below. We will promptly delete the information upon learning that it relates to a child under the age of 13. Please note that it is possible some of this information may remain archived in web logs and back-up archives after we delete the information from our active database. 

11. Business transitions 

In the event we go through a business transition, such as a merger, acquisition by another company, or sale of a portion of our assets, users’ personal information will, in most instances, be part of the assets transferred. In such instance, the new owners may use your personal data in the same way as set out in this Privacy Policy.

12. California user consumer rights

In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. Under California law, California residents who have an established business relationship with us or one of our subsidiaries may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email support@freeagentcrm.com.

13. Users located outside of the United States

We make an effort to protect the personal information of all users of our Website.  If you are unsure whether this privacy policy is in conflict with the rules applicable where you are located, you should not submit your personal information. IN ADDITION, IF YOU ARE LOCATED WITHIN THE EUROPEAN UNION, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY THE EUROPEAN UNION TO HAVE INADEQUATE DATA PROTECTION. Users of our Website located in countries outside of the United States who submit personal information do thereby consent to the transfer of that information to and/or storage of the information in the United States.

14. EU users’ rights under the GDPR

 If you are located in the European Union, or if the EU’s General Data Protection Regulation (“GDPR”) otherwise applies to your data as processed by us, you have the right to:

  1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and our full list of third parties who process your data, and to check that we are lawfully processing it.
  2. Request confirmation as to whether or not your personal data is being processed.
  3. Request correction of your personal data that you consider to be inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you provide to us.
  4. Request erasure of your personal data. This enables you to ask us to delete or remove personal data, for example: i) where there is no good reason for us continuing to process it; ii) where you have successfully exercised your right to object to processing (see below); iii) where we may have processed your information unlawfully; iv) 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 and our need to keep appropriate archives for our business operations. These reasons will be notified to you at the time of your request. In addition, as explained in Section 2.3, certain information may always be publicly available to others and other information is made publicly available to others by default.
  5. Object to processing of your personal data. This enables you to object to the processing of your personal data if you feel it impacts on your fundamental rights and freedoms. For example, this can be where we are processing your personal data for direct marketing purposes. In some cases, we may have compelling legitimate grounds to process your information which can override your right to object.
  6. Request restriction of processing of your personal data. This gives you the option to ask us to suspend the processing of your personal data in the following scenarios: i) if you want us to establish the data’s accuracy; ii) where our use of the data is unlawful but you do not want us to erase it; iii) where you need us to hold the data, even if we no longer require it e.g. to establish or defend legal claims; or iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate ground to use it.
  7. Request transfer of your personal data. If you request us to do so, we will provide to you, or a third party of your choice, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we have used the information to perform a contract with you.
  8. Withdraw consent to the processing of your data. If you request us to do so, we will no longer process your 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 our Service for you. Also, we will advise you of this at the time you withdraw your consent.
  9. Not have a decision made about you based solely on automated processing.

If you wish to exercise any of the rights set out above or request details about the specific legal basis we are relying on to process your personal data, please email us at support@freeagentcrm.com using the Subject Access Request Form.

We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days 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.

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 your other legal rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the 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.

You will not have to pay a fee to access your personal data (or to exercise any of your other legal 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.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please email us at support@freeagentcrm.com in the first instance.

15. Data retention

If you are located in the European Union, or if the GDPR otherwise applies to your data as processed by us, we will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or internal 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. We typically retain Email Account Data for three (3) years, after which it is deleted permanently.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.

16. Cooperation with law enforcement; fraud protection

 We fully cooperate with law enforcement agencies in identifying those who use our Website or Service for illegal activities. We reserve the right to disclose information about users who we believe are in violation of applicable laws or regulations, or as required to respond to a subpoena, court orders or other legal process requiring such disclosure. We also reserve the right to report to law enforcement agencies any activities that we reasonably believe to be unlawful and to exchange information with other companies and organizations for fraud protection.

17. Vulnerability Disclosure

At the FreeAgent CRM, we consider the security of our systems a top priority. But no matter how much effort we put into system security, there can still be vulnerabilities present.

If you discover a vulnerability, we would like to know about it so we can take steps to address it as quickly as possible. We would like to ask you to help us better protect our clients and our systems.

Please do the following:

  • E-mail your findings to support@freeagentsoftware.com.
  • Do not take advantage of the vulnerability or problem you have discovered, for example by downloading more data than necessary to demonstrate the vulnerability or deleting or modifying other people’s data,
  • Do not reveal the problem to others until it has been resolved,
  • Do not use attacks on physical security, social engineering, distributed denial of service, spam or applications of third parties, and
  • Do provide sufficient information to reproduce the problem, so we will be able to resolve it as quickly as possible. Usually, the IP address or the URL of the affected system and a description of the vulnerability will be sufficient, but complex vulnerabilities may require further explanation.
  • Avoid violating the privacy of others, disrupting our systems, destroying data, and/or harming user experience;
  • Use only the Official Channels to discuss vulnerability information with us.
  • Keep the details of any discovered vulnerabilities confidential until they are fixed, according to the Disclosure Terms in this policy.
  • Perform testing only on in-scope systems, and respect systems and activities that are out-of-scope.

Official Channels

To help us receive vulnerability submissions we use the following official reporting channels:  support@freeagentsoftware.com email address.

18. Changes to this Privacy Policy

Occasionally we may, in our discretion, make changes to this Privacy Policy. When we make material changes to this Privacy Policy, we will provide you with prominent notice as appropriate under the circumstances, e.g. by displaying a prominent notice within the Website or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Service after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you object to any of the changes, you have the opportunity to delete your account and any associated information. Once deleted your details will be non-recoverable.

Please note that if you opt out of receiving notices from us, change notices will still govern your use of the Service, and you are responsible for reviewing such legal notices for changes, as posted on the Website.

19. Who we are

For the purposes of the GDPR, Free Agent Network, Inc., a Delaware corporation located at 1203 N Rouse Ave, Bozeman, MT 59715, USA is the Data Controller and is responsible for your personal data. This means that we determine the purposes and ways of the processing of your personal data.

Effective as of March 25, 2019
To view our previous Privacy Policy, click here

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