At various times Freeman may collect personal information, such as your email address, name, home or work address or telephone number, VAT number, financial and credit card information or anonymous demographic information. This is information you give Freeman by filling in forms on the Site, registering on the Site or placing an order online. It also includes personal information you provide to us offline, such as when you attend an exhibition, trade show or event, place a verbal order over the phone, contact customer service or visit one of our offices.
There is also information about your computer hardware and software that may be automatically collected by Freeman. This information can include: your IP address, your login information, browser type and version, browser plugins, domain names, products or services you viewed or searched for, download errors, clickstream history through and from the Site, access times and referring website addresses. This information is used by Freeman for the operation of the service, to conduct business activities, to maintain quality of the service, and to provide general statistics regarding use of the Site. We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive or provide information about you from them.
We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. More specifically, Freeman [itself, its affiliates, and/or contracted third parties] collects, uses, transmits and stores the personal information you provide to deliver the services you have requested; to inform you of other products or services available from Freeman; to notify you about changes to our service; and to ensure that content from the Site is presented in the most effective manner for you and for your device. Freeman also may use your personal information to operate the Site; for internal operations, including troubleshooting, data analysis and testing; or to contact you via survey to conduct research about your opinion of current services or of potential new services that may be offered.
Except as set forth in this policy, Freeman will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Freeman, its licensees or the Site; (b) protect and defend the rights or property of Freeman; and, (c) act under exigent circumstances to protect the personal safety of users of Freeman, the Site, or the public. Freeman may provide your personal information to (a) Freeman affiliates, contractors, and/or service providers that are located overseas which may not be bound by to US privacy laws; and (b) anyone authorized by you to receive your personal information.
Freeman may aggregate and amalgamate your personal information with other data, for internal reporting purposes, to improve the delivery of services and for benchmarking services. Freeman will only use your personal information under circumstances where you will not be, and could not reasonably be, identified as the source or origin of the information.
Freeman will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Freeman secures the personal information you provide on servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. Personal information is transmitted to other websites through the use of Transport Layer Security (TLS) encrypted protection. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site; any transmission is at your own risk. Once Freeman has received your personal information, Freeman will use strict procedures and security features to try to prevent unauthorized access.
From time to time, Freeman reviews its security procedures in an effort to make the security of personal information better. However, please be aware that no security measures are perfect or impenetrable.
If there are material changes to this Policy or in how Freeman will use your personal information, Freeman will prominently post such changes prior to implementing the change. Freeman encourages you to periodically review this Policy to be informed of how we are protecting your information. This Policy was last updated on March 12, 2019.
Freeman welcomes your comments regarding this Policy. Please contact Freeman by telephone, email or postal mail if you have any questions or concerns regarding this Policy, its implementation or would like to update your personal information:
P.O. Box 660613
Dallas, TX 75266-0613
All complaints will be responded to within 45 days. Dispute resolution service is free of charge under Privacy Shield. If a complaint remains unresolved, you should contact your state or national data protection or labor authority for resolution. A listing of the European Union Data Protection Authorities (“DPAs”) is located at: http://ec.europa.eu/justice/data-protection/article- 29/structure/data-protection-authorities/index_en.htm Freeman will cooperate with the competent DPAs and comply with their advice. In the event that the DPAs determine Freeman did not comply with its Policy or the Privacy Shield principles, Freeman will take appropriate steps to address any adverse effects and to promote future compliance, comply with any advice given by the DPAs where the DPAs have determined Freeman, needs to take specific remedial or compensatory measures for your benefit because of any non-compliance with this Policy or the Privacy Shield principles. Freeman will also, provide the DPAs with written confirmation such action has been taken.
California’s “Shine the Light” Law
If you are a California resident and wish to review or change the personal information of yours which Freeman possesses, please contact us by one of the ways listed above in the Contact Information section.
US Law Applies
The Site is governed by and operated by Freeman from its offices in the United States and in accordance with the laws of the United States. If you are located outside of the US, you use the Site at your own risk. Freeman is a company that operates globally so it may be necessary to transfer your personal information internationally in accordance with this Policy. In particular, your personal information will be transferred to and processed in the United States where many of our central databases operate. By using the Site and the services related thereto, you (a) acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive standard of protection than those in your country; (b) consent to your personal information being collected, processed and transferred as set forth in this Policy and US law; and (c) submit to the jurisdiction of, and agree that venue is proper in Dallas County, Texas, USA in any legal action or proceeding. Freeman is also subject to the regulation and enforcement under the United States Federal Trade Commission.
EU-US Privacy Shield Framework
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Freeman is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Freeman’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Freeman remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Freeman proves that it is not responsible for the event giving rise to the damage.
Freeman commits to resolve complaints about your privacy as detailed above and we further commit to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.