The Freeman group of companies which trade in Asia (referred to as “Freeman” “we”, “us”, “our”) are committed to protecting and respecting your privacy rights under the applicable Data Protection Laws (as defined in the below Privacy Statement) in your jurisdiction. This PICS sets out our privacy practices. Please read this PICS and the below Privacy Statement (“Privacy Statement”) carefully.
Capitalized terms used but not defined in this PICS have the meanings given to them in the below Privacy Statement.
- Information we may collect from you and the purposes
"personal information" refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Below are some examples of personal information we may collect from you:
- your full name; and
- your contact details (including address, telephone number, e-mail or social media address) and proof of the same.
We will collect, use and transfer to third parties your personal information for the purposes as set out in the below Privacy Statement.
- Direct marketing
You consent to us using, from time to time, your personal information (for example, your address, telephone number and/or email address) to promote and market our merchant and related services and products and/or any loyalty, co-branding or privileges programmes and related services we offer. You also consent to us sharing, from time to time, your personal information (for example, your address, telephone number and/or email address) with our related companies and venue partners including but not limited to Freeman’s United States parent and affiliate companies for direct marketing purposes. In relation to our use of your telephone number we may contact you by voice calls, texts, electronic messages, fax or other means with information about other events, promotions, products or services that Freeman believes would be of interest. If you do not want Freeman to use or share your personal information for direct marketing purposes as described above, please do not indicate acceptance of our PICS or continue to use this platform. If you indicate acceptance now and later change your mind about your preference, please let us know then at the contact details specified in Clause 7 of the below Privacy Statement. After your request has been processed by us, we may still contact you for other purposes in relation to the goods or services provided by Freeman to you or as set out in other sections of the PICS and/or the below Privacy Statement.
- Where we store your personal information
We may transfer your personal information to, and store it in or outside the jurisdiction in which you are based. For example, where you are based in China, your personal information may be transferred outside of China. Your personal information may also be processed by our suppliers or third party service providers. By providing us with your personal information, you consent to this transfer, storing or processing and as disclosed in the below Privacy Statement. In order to prevent unauthorised access or disclosure, we have implemented technical and organisational security measures to protect and secure your personal information and ensure that it is used only in accordance with this PICS, the below Privacy Statement and applicable Data Protection Law.
By providing us with your personal information, you consent to the disclosure, storing and processing as described above. We aim to ensure that your personal information is treated securely and in accordance with this PICS and the below Privacy Statement. We will retain the personal information only until it is no longer required for the purposes set out in this PICS and the below Privacy Statement.
- Your data privacy rights
Subject to the applicable Data Protection Law and as further described in the below Privacy Statement, you may request to access, to make duplications of (at the required cost), supplement, correct or delete, your personal information held by us, or enquire or complain about our data protection policies and practices, or request to discontinue our collection, processing or use of your personal information, at the contact details specified in Clause 7 of the below Privacy Statement, and we will process your request within a reasonable time from the request unless we have reasonable grounds not to do so. Your request may result in certain consequences which we will notify you of upon receipt of your request, for example: Freeman may not be able to provide or continue to provide you with certain goods or services that you have requested.
In the event of conflict between the English and any other language version of this PICS and the Privacy Statement the English version shall prevail.
The Freeman group of companies trading throughout Asia (Freeman Group) which includes but is not limited to the following companies:
Freeman Pte. Ltd.
Freeman Brand Promotion & Consulting (Beijing) Co. Ltd.
(each Freeman Group company called Freeman/we/us/our) aims to protect the privacy of the personal information (or ‘personal data’ as defined under the applicable Data Protection Law (personal information)) that we collect and hold while carrying out our activities.
This Privacy Statement covers our data protection practices in the above jurisdictions.
Freeman is also bound by data protection, privacy or other data security laws, ordinances and/or regulations applicable and in force in the respective jurisdiction in which it operates (Data Protection Laws). This statement has been developed as part of Freeman’s efforts to achieve its policy goal and to comply with its obligations under those Data Protection Laws.
This statement applies to ‘personal information’ which is collected from and relates to an individual staff member, client, potential client, previous client, supplier and any other person whose personal information Freeman may collect from time to time. Platforms on which personal information will be collected include but are not limited to Freeman Group’s websites such as www.freeman.com, or any mobile application made available by Freeman and from those who provide their personal information via third parties.
This statement explains what types of personal information we might collect, how we aim to use personal information, how we process personal information, when we will disclose personal information to others, how we store, retain and secure personal information, how you can access and seek to correct personal information that we hold about you, and how you may make a complaint if you think that we have breached the applicable Data Protection Law.
This statement does not form part of any contract except to the extent that we expressly specify that it does.
From time to time, we may review and update this Privacy Statement – for example, to reflect changes to the law, Data Protection Law, technology or our companies. You should check the version of this Privacy Statement available on our websites periodically to read about any updates. We may generally notify users of any updates by including a “Newly Updated” label with the Privacy Statement link on our websites for a period of 30 days and we may seek your consent (if necessary).
In some jurisdictions, this Privacy Statement may not apply to Freeman’s treatment of employee records, where the treatment is directly related to a current or former employment relationship between Freeman and an employee but only to the extent that such employee records are not subject to applicable Data Protection Law.
What types of personal information do we collect?
Freeman collects ‘personal information' (or ‘personal data’ as defined under applicable Data Protection Law) that is reasonably necessary for its activities.
Personal information collected by Freeman includes but is not limited to:
- information about:
- clients and potential clients, and clients of venue operators with which we work;
- clients’ attendees, visitors, exhibitors and others who register in relation to functions, events, exhibitions or other activities or on a website or mobile app established or administered by any of the Freeman Group or any of its related companies, (collectively called 'Clients and Visitors');
- information about job applicants and staff members;
- details of other people who come into contact with Freeman such as suppliers, subcontractors and other service providers, sponsors, advertisers, agents, and business associates (collectively called 'Suppliers'); and
- information about officers, employees and other representatives of corporations that Freeman deals with (collectively called 'Personal Representatives').
The types of personal information we may collect will depend on the nature of the interaction with Freeman, and where and how we collect the information but may include:
- names, addresses, email addresses, roles, telephone and fax numbers and other contact details and means of communication with;
- details about company or industry and also information about your use of Freeman’s services;
- identifying details such as gender, date of birth, personal attributes, nationality, passport/identification card number and country of residence;
- payment information such as credit or debit card information, including the name of cardholder, card number, card issuing bank, card issuing country and expiry date; banking account details;
- when you interact with any of Freeman Group’s websites or mobile applications, technical information such as IP address or for applications your location and mobile device.
If some personal information that Freeman requests is not provided, Freeman may not be able to provide you with certain goods or services or engage you to work for Freeman.
Some of the information we collect may amount to 'sensitive information' (as defined under applicable Data Protection Laws) such as information about your age, colour, marital status, membership of a professional or trade association, racial or ethnic origin, philosophical, political or religious beliefs (or others of a similar nature) or affiliation, physical or mental health, genetic or sexual life, or commission (whether alleged or not) of an offence of any other personal data as determined by the authorities. We will aim to only to collect sensitive information (as defined under applicable Data Protection Laws) from you where this is explicitly consented to by you and reasonably necessary for our activities, or if the collection is required by law or a court or tribunal order, or if the information has been deliberately made public by you, and only to share sensitive information if Freeman believes that its use, processing or disclosure is necessary:
- to lessen or prevent threats to health, life or safety, or protect the vital interests, of any individual;
- for medical purposes, undertaken by (a) a healthcare professional or (b) a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a healthcare professional;
- to investigate unlawful activity or serious misconduct;
- to assist enforcement bodies, such as the police, with their activities;
- to assist in locating a missing person;
- to establish, exercise or defend a legal or equitable claim or rights, or obtain legal advice;
- for the purpose of or in connection with legal proceedings;
- for the administration of justice, for the exercise of any functions conferred under any applicable law, or for any other purpose allowed under applicable Data Protection Laws;
- to exercise or perform any right or obligation which is conferred or imposed by law on us in connection with employment; and/or
- for the purpose of confidential alternative dispute resolution.
We generally collect personal information directly from you, for example when you send us correspondence by e-mail or in writing, deal with us over the telephone or in person, contact us, request a quote or information, provide online feedback, or register or provide contact details in relation to an event, function, exhibition, promotion or other activity through one of our websites or mobile apps established or administered by us or any related company (collectively called ‘Websites’)
We do not collect personal information from visitors on our Websites other than what is supplied to us on a voluntary basis, or technical information as set out in this Privacy Statement.
Sometimes, someone else may provide us with personal information about you, with or without your direct involvement. For example, we might collect your personal information from:
- your employer if it provides your contact details;
- a hotel or other venue operator or its representatives;
- another organisation of which you are a member;
- a contractor or supplier;
- your representative;
- publicly available sources of information (such as telephone directories or websites); or
- publicly and commercially available mailing and marketing lists.
Information of Clients and Visitors, Suppliers and Personal Representatives
Personal information is collected from Clients and Visitors, Suppliers and Personal Representatives, to enable Freeman to conduct its business. The purposes for which Freeman uses personal information of Clients and Visitors, Suppliers and Personal Representatives include (but are not limited to):
- to provide quotations for provision of its services and/or products;
- to provide them with its services and/or products;
- to improve and develop its services and/or products;
- to provide ongoing support or help to manage its services and/or products, for example if they have a query;
- to obtain services and/or products or obtain information about services and/or products;
- to bill, collect payment or make payment including for the purpose of accounting and account administration and auditing;
- to communicate with them;
- to provide information about other products or services that Freeman considers would interest them (which they can tell Freeman not to do at any time);
- to help Freeman run its business, for example to improve its products or services, security, safety or operations, to conduct training, to undertake marketing activities or statistical or marketing analysis and customer surveys, to manage information systems, test, develop and maintain systems and security controls; and
- to comply with its legal obligations.
If we collect your personal information to be used for any other purpose, we will aim to let you know that purpose at the time we collect the information.
Information of job applicants and staff members
Freeman collects personal information of job applicants and staff members for the primary purpose of assessing and (if successful) engaging the applicant or staff member as the case may be.
The purposes for which Freeman uses personal information of job applicants and staff members include:
- comparing against job specification or criteria and assessing suitability for employment and generally for the processing of an employment application;
- internal and external investigations including disciplinary, grievance, and regulatory issues;
- carrying out checks such as prior employment, academic, medical and police record checks;
- managing individual’s employment or engagement and the provision of employee references;
- insurance purposes;
- ensuring that we hold relevant contact information;
- intra-group communications, and strategic, financial and business planning and operations within Freeman;
- monitoring compliance with legal requirements, internal rules or contractual obligations of Freeman;
- human resources management purposes, such as: onboarding, the planning and implementation of staffing and training, performance assessments, promotions, transfers, secondments and other career-related matters, the review, implementation and administration of our staff benefits, payroll administration and termination; and
- other purposes directly relating to any of the above.
Freeman may also use personal information in order to provide you with information about other events, promotions, products or services that we believe will be of interest. You can let us know if you change your mind about receiving such communications at any time at the contact details set out in Clause 7 of the Privacy Statement below. Your request may result in certain consequences which we will notify you of upon receipt of your request, for example: Freeman may not be able to provide you with certain services that you have requested. After your request has been processed, we may still contact you for other purposes in relation to the goods or services provided by Freeman to you or as set out in other sections of the Privacy Statement.
We do not sell personal information. We may share anonymous or aggregated information which does not identify individuals and cannot be recovered, with third parties.
Freeman aims to confine its disclosure of personal information to the primary purpose for which it has been collected, or for a related purpose. This means Freeman will usually only disclose personal information in connection with its business and administrative functions, including when disclosure is necessary to provide you with a product or service that you have requested, to help us with the running of our organisation, or for security reasons.
Sometimes we may also disclose your personal information outside Freeman for the purpose for which the information was collected, or for a related purpose – for example when disclosure is necessary to provide you with a product, service or activity you have requested, to help us with the running of our organisation, or for security reasons or comply with the law.
We may provide your personal information to:
- organisers, promoters and sponsors of functions, events or exhibitions;
- hotel or other venue operators and their representatives in relation to functions, events or exhibitions;
- our clients in relation to their functions, events or exhibitions;
- companies related to Freeman that are located outside of the jurisdiction in which you are based in, for example: in Australia, the United States of America, Canada, China, Hong Kong, United Kingdom, Middle East, and Singapore;
- outsourced subcontractors, service providers and other suppliers and agents who perform functions on our behalf, such as organisations providing event related goods or services, banking or financial services, internet hosting services, cloud based applications or data networks, event registration services, security services, audit services, legal services, insurance services, market research services and email or mail handling services, and representatives and agents who sell or promote goods and services on our behalf. Some of these organisations are located outside of the jurisdiction in which Freeman has collected your personal information and may not be bound by the Data Protection Law applicable in that place;
- business partners or service providers who may sell goods and services which do not belong to us but which you have elected to obtain;
- anyone authorised by you to receive your personal information (your consent may be express or implied and can be withdrawn at any time);
- an actual or prospective purchaser or seller, if we sell any part of our business or company, merge or acquire another business or company; and
- anyone to whom we are required by law to disclose personal information.
In addition to the purposes set out above, subject to the provisions of any applicable law, personal information of job applicants and staff members may also be:
- supplied to any agent, contractor or third party who provides administrative or other services in or outside of the jurisdiction in which you are based, and who has a duty of confidentiality to us such as for example : medical practitioners, pension providers, payroll providers, actuaries and any consultants/agents appointed by Freeman to plan, provide and/or administer employee benefits;
- supplied to persons seeking employee references; and
- disclosed to any government departments or other appropriate governmental or regulatory authorities in or outside of the jurisdiction in which you are based
We aim to ensure that such third parties only use your personal information for the specific purpose for which it was given to us and to protect the privacy of your personal information. Transfer of your personal information will be made for one or more of the purposes specified above and in this regard to the extent that it remains a requirement to do so in the relevant jurisdiction, we will seek your consent to the transfer of your personal information outside of the jurisdiction that you are based in prior to transferring your information.
The headquarters of Freeman’s parent companies are located in the United States of America. In Asia, we store personal information on a cloud-based network with the server currently located in Singapore which storage may comprise a transfer outside of your jurisdiction under the Data Protection Laws applicable to your personal information.
When you visit the public pages of our Websites, our Website servers make a record of your visit and log the following information;
- your Internet Protocol address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
- search terms used;
- the operating system and Internet browser software you are currently using; and
- the data that you download (such as web pages or other document files or software), and the time that you download it.
This information cannot be used to identify you and is only used for statistical purposes to help us identify what parts of our Website our users visit the most, which in turn assists us to determine how to improve our services.
If you contact us, register through any of our Websites or email us, Freeman aims to only use your personal information to respond to your request or answer your queries. Subject to the provision of your consent where required by applicable law, we may also add your email address to our mailing list, however you can let us know if you change your mind about receiving information about Freeman, our events, promotions products and/or services.
We use two types of cookies. A session cookie expires when you close your browser. A permanent cookie remains on your hard drive until it expires or until the computer user logs out from our Website. You can also remove permanent cookies by following directions provided in your Internet browser’s “help” file. The "help" feature in most browsers provides information on how to prevent your browser from accepting new cookies, how to turn on the notification for new cookies, and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on's settings or by visiting the Website of the add-on's manufacturer. As cookies allow you to take advantage of some of the Website’s essential features, we recommend that you accept cookies.
We may also utilise cookies to track the effectiveness of online advertising where applicable. This information is aggregated and does not identify individuals. Freeman may use this information to make informed decisions with regard to the purchase of any such online advertising.
It is important that you prevent unauthorised access to your password and your computer. You should always log out after using a shared computer to access our Websites.
To the extent that our Websites contain links to sites operated by third parties, including other organisations, those linked websites are not controlled by us and we are not responsible for the data and privacy practices of the site operators.
Freeman may also administer or maintain websites or mobile applications for third parties, including administering or maintaining a website or mobile application for a client in relation to the client’s exhibition or event. Those websites are owned by our clients or other third parties, and those mobile apps are specific to our clients’ or other parties’ exhibitions or events and Freeman is not responsible for the privacy practices of its clients and other parties.
Where it is a legal or regulatory requirement in your jurisdiction, a Privacy Officer or a Data Protection Officer (“Privacy Officer”) has been appointed. The respective Privacy Officers are responsible for managing any issues with personal information collected by the respective Freeman company in the specified locations, including any of your requests for access or correction to your personal information, and if you would like to enquire or change your preference to how we use and process your personal information.
The Privacy Officer for your jurisdiction can be contacted at the following email address: firstname.lastname@example.org
Freeman’s staff are required to respect the confidentiality of all personal information and the privacy of individuals, and we have directed our staff that personal information must be dealt with in accordance with this Privacy Statement.
Freeman has security systems in place which are intended to protect your personal information from misuse, loss, unauthorised access, modification or disclosure by the use of various methods including, for example, an IT system which ensures only authorised computers and employees are granted access to our computer network and a security policy which controls what folders and files employees have access to.
If Freeman receives personal information about you which it did not request and which it does not reasonably require, Freeman may destroy or de-identify this information where appropriate.
Freeman aims to keep all personal information that we hold accurate, complete, not misleading and up-to-date. We encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete, misleading or out-of-date, please contact the relevant Privacy Officer as indicated above. We will process your request as soon as practicable after the request has been made unless we have reasonable grounds not to do so. Unless it is not permitted by applicable Data Protection Laws, or not required for legal or business purposes, we may also send the updated personal information to every other organisation to which the personal information was disclosed by us within the year before the date the correction was made.
Freeman is required by law to keep some types of information for certain periods of time. If we no longer require your personal information, we may have an obligation to destroy or de-identify that information. Freeman reserves the right to retain information for a period longer than that for which it is required to retain the information if Freeman considers that it is necessary for its functions, and as long as it is in accordance with applicable Data Protection Law.
You may have the right to obtain access to any personal information which Freeman holds about you, to advise Freeman of any perceived inaccuracy in that information and to request correction of that information. There may be some exceptions to this right under applicable Data Protection Laws in a relevant jurisdiction.
In some circumstances, applicable Data Protection Laws may entitle Freeman to deny access, for example, where the burden or expense of providing access is not proportionate to the risk of your privacy or if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which we are involved. If we do refuse access, we will generally let you know the reasons for our refusal (unless it is unreasonable to do so, in accordance with applicable Data Protection Laws). We will generally process your access request within the timeframe provided in the applicable Data Protection Laws, or we will inform you of the reasonably shortest period of time in which we will respond to the request.
If you make a request for access to your personal information, we may ask you to verify your identity and specify what information you require. If permissible under applicable Data Protection Laws Freeman may charge a fee, which will be assessed on a case-by-case basis by Freeman, to cover our costs of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, Freeman will generally advise the likely cost in advance. Please note that we may only process your request once you have agreed to the payment of the fee and where permissible under applicable Data Protection Laws, where you have paid that fee.
To make a request to access any information that Freeman holds about you, please contact us in writing using the contact information provided in Clause 7 above.
If you have a complaint about Freeman’s compliance with applicable Data Protection Laws, please contact us or our relevant Privacy Officer in your location as indicated above, in writing.
We cannot distinguish the age of visitors to our Websites. If you are a parent or guardian of a minor who has provided us with his/her personal information without your knowledge and consent, you may request that we remove such information by contacting us. The age of minors for the purposes of this Privacy Statement is 18 years or under except for residents in the following jurisdictions where the age of minors is as follows:
- China: 16 years or under
- South Korea: 14 years or under
- Taiwan: 20 years or under
To the extent permissible under applicable Data Protection Laws by using or accessing any of our Websites or providing us with personal information:
- you consent to the collection, use and processing of your personal Information by Freeman in the ways described above (which may change from time to time) unless and until you inform us to the contrary. You may submit a request to withdraw your consent at any time by informing us in writing that you withdraw that consent ; and
- you consent to us disclosing or transferring your personal information to the third parties and other Freeman Group companies in the ways described above. You can withdraw your consent at any time by informing us in writing that you withdraw that consent.
If you have provided us with personal information of third party individuals, you are required to obtain the individual's prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their personal information to us. By providing us with personal information of third party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Privacy Statement.
To the extent that additional consent is required by applicable Data Protection Law:
- Freeman or any third party service providers engaged by us will aim to obtain your consent to collect and use your personal information at the time of collection;
- Freeman will adopt an ‘opt-in' policy to obtain your express written consent when collecting your personal information. You may be asked, for example, to sign a form or tick a box on a Website.
If you do not permit the collection, use, processing, transfer or disclosure of some personal information as Freeman has notified or requests, Freeman may not be able to meet its legal obligations or may not be able to do business with you or engage you to work for Freeman. If that is the case, we will let you know. In most instances, it is obligatory for you to provide us with your personal information in order to allow us to satisfy your request or provide you with the service that you have requested. However, you may let us know if you no longer wish to receive marketing, communications, promotional offers, newsletters or any other similar communications from Freeman and we will process your request within a reasonable time upon our receipt of your notification.