Effective as of 2 May 2019
This website (the “Site”) is operated by Freenet Digital LLC, a Delaware limited liability company
regarding the information collected in connection with your use of the Site and any other sites,
applications, features, content or promotions offered by us from time-to-time that link or
with respect to all information that we have collected, or in the future collect, from you, whether
as a guest or a registered user (including without limitation any buyer or seller).
By accessing and/or
reference and to comply with all applicable laws, rules and regulations (collectively, “Applicable
Information We Collect
- Information You Provide to Us.
When you submit an online form, engage in live chat, set up
an account, register or subscribe to a Service, enter a sweepstakes or contest, request
information from us, request a free consultation, purchase goods or services or otherwise
communicate with our support personnel via forms, email, text, fax, or phone, you may
provide us with information. Such information may include, for example, your name, email
address, phone number, physical address and financial or business information. This may also
include information you provide us about other people. We also store the files or other
information that you may upload or provide to use with the features and functionality of the
Services, for example, your client lists and communication contents (“Customer Content”).
By providing us with this information, you consent to your information being collected, used,
- Information From Your Use of the Services.
We also collect technical and usage information
when you use the Services, including, without limitation, information obtained using various
types of tracking software, such as cookies, beacons, pixels and other tracking technology
which collect information about you when you visit our Site or otherwise use the Services.
Information collected may include your browser type and version, IP address, operating
system and platform, your internet service provider, when you open email that we send you
or interact with an advertisement and other information. We may collect and store
information locally on your device using mechanisms such as browser web
storage and application data caches. In addition, if you access the Service from a mobile or
other device, we may collect a unique device identifier assigned to that device, geolocation
data (including your precise location), or other transactional information for that device. By
visiting the Services, you consent to the tracking of your activities and your use of the Services
used or developed in the future.
If you post or share information or content on or through the Services,
such as in comments or forums, this information and any accompanying identifying
information, will be considered non-confidential and non-proprietary, will be available
publicly. We cannot prevent further use of this information once it is made public. By posting
information or content any on or through the Services, you grant us and our affiliates and
service providers, and each of their and our respective licensees, successors and assigns the
right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third-
parties any such material for any purpose, including, without limitation, commercial and
promotional purposes without additional compensation or consent.
- Information From Other Sources.
We may obtain information about you on the Internet or
through offline sources or other public or commercial sources including, without limitation,
from the information you have provided on social media services or when you interact with
our content through a social media service. If you access the Service through a third-party
service (e.g., Facebook, Twitter), connect the Service to a third-party service or share our
content via a third-party service, you are authorizing us to collect, store, and use such
online information with information we obtain from information from our partners and from
offline sources, including, without limitation, information that you may provide us with over
the phone or in person.
How We Use Your Information
We may use your information, including, any personal information (i.e., information that identifies
a specific person, such as full name or email address), as follows:
- To provide the Services to you and other users, including, without limitation, to provide you
with information, support, products or services that you request from us.
- To communicate with you and others, for example, to provide you with information, about
your account or other products or services and notify you about issues with or changes to the
Services or our policies. You agree that Company or our agents may email, call or text you
regarding your account or your transactions and that we may listen to and record phone
conversations you have with us, for example, for training purposes or to evaluate the quality
of our service.
- To market and promote the Services or our other third party promotions, products and
services to you, including, jointly with third-party marketing partners and/or service
- To allow you to share and collaborate on content.
- To display and target advertisements and content on the Services and on third-party services.
- In combination with information we obtain from other sources, including, without limitation,
- To analyze and improve the Services and your user experience on the Services, including,
personalization of the Services, and to develop new Services.
- To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including, for billing and collection.
- To protect the rights and safety of ourselves and others, including to detect, investigate and
- To fulfill any other purpose for which you provide the information or otherwise consent.
- To comply with laws such as to comply with a subpoena, regulations, court or administrative
orders and/or to protect our rights, protect your safety or the safety of others, investigate
fraud, or respond to a government request.
- Upon a transfer or sale to another entity of all or substantially all of our stock or assets in the
How We Share Your Information
If you request a consultation with us, then your email address, name, phone number and other
details you provide may be shared with selected third-parties who we believe may be able to
assist with providing a solution to the issue which is subject of the consultation. If, for example,
you request a debt consultation with us, then your email address, name, phone number and other
details you provide may be shared with selected third-parties who we believe may be able to
assist with working towards a solution to your debt. Where we permit selected third parties to
use your data, we (or they) will contact you by phone, e-mail and SMS messaging only if you have
consented to this. When we refer your details to a third party-company, we may receive financial
compensation for doing so. However, we do not charge you for this introduction. Your
consultation is always free, but fees will apply if you choose to enter into a debt program. These
fees will be made clear by your advisor prior to your enrollment. We may also share your
information (including personal information that identifies you) as follows:
- To allow service providers, agents and other third-parties to assist in providing and managing
- To provide information to our representatives, advisors, corporate affiliates and business
partners, including without limitation to other companies so that they can market their
products or services to you.
- With our third-party sponsors and marketing partners in connection with co-promotions or
for their own use.
- For collaboration when you choose to use collaboration or sharing features of the Services.
- To provide advertising on the Services and third-party sites and services.
- In connection with a business transaction, for example, an acquisition, merger, sale of an asset
or line of business, corporate reorganization or bankruptcy.
- For legal and law enforcement purposes, for example, in response to a court order, subpoena
or law enforcement agency request, to prevent fraud or abuse of the Services or protect the
safety of ourselves or others.
- When you have otherwise provided your consent to do so.
- For information that does not identity you as a specific person, we may use and share it with
third-parties for any purpose.
Without limiting the foregoing, by providing your personal information on the Site, you agree that
such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing
Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state
do-not-call regulations. As such, notwithstanding that your telephone number may be listed on
the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we
retain the right to contact you via telemarketing, including by means of a pre-recorded message
and automated voice dialing, in accordance with the Rule and the applicable state do-not-call
regulations. Your acceptance of the terms and conditions of this Site constitutes your express
written consent to receive telemarketing calls from third-party marketers, including by means of
a pre-recorded message and automated voice dialing. Your consent will be effective regardless of
whether the number you have provided: (a) is a home, business, or cell phone line; or (b) is or will
be registered on any state or federal Do-Not-Call (DNC) list.
If you upload and/or store Customer Content, including, without limitation, your client
information and communications, in the Services, such Customer Content will be subject to the
additional terms and conditions and confidentiality obligations, set forth in your service
agreement with us.
If you submit suggestions, ideas, enhancement requests, recommendations or other feedback
(collectively, “Feedback”) in connection with the Services, Company will have the unrestricted
right to use or act upon such Feedback and such Feedback will not be considered confidential.
If you do not wish to receive any further marketing
communications from us, you may opt-out by clicking the unsubscribe link or following the
instructions included in the communication. Please note, however, that you cannot opt-out
of certain administrative communications from us. To opt out of marketing communications
from our third-party partners you may contact each of them directly with this request.
Some advertisements and other content may be delivered by third-party
ID for mobile devices to collect and track information such as demographic information,
inferred interests, aggregated information, and activity to assist them in delivering advertising
that is more relevant to your interests. To find out more about third-party advertising
networks and similar entities that use these technologies, see www.aboutads.info . If you would like to opt-out of such ad networks’ and services’ advertising practices, go to
www.aboutads.info/choices to opt-out in desktop and mobile web browsers. You may
download the AppChoices app at www.aboutads.info/appchoices
to opt-out in mobile applications.
Your California Privacy Rights.
California Civil Code Section § 1798.83 permits users of the
Services that are California residents to opt-out of our disclosure of personal information to
third-parties for their direct marketing purposes. To make such a request, send an e-mail with
the subject line “California Privacy Rights” to email@example.com and include your full
name, email and postal address. In addition, any California resident under the age of eighteen
(18) who has publicly posted content or information on the Services can request removal by
sending an email with subject line “California Content Removal” to
firstname.lastname@example.org and include your full name, email, postal address, a description of where the content or
information is posted and a statement that you posted it. We will make good faith efforts to
comply with such requests with respect to content or information posted on the Services.
However, please be aware that there may be circumstances where we are unable to remove
such content or where the law does not require or allow such removal even if requested.
You may turn off part or all of our tracking software which has been
placed on your computer by following the instructions on your browser. On mobile device,
you may turn off part or all of mobile tracking through your mobile device settings. However,
if you prevent the use of tracking software or tracking through your mobile device, it will be
more difficult, and may be impossible, for you to use the Service or portions of the Services.
Some of the Services also use Google Analytics. For more information about Google Analytics
cookies visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-
usage. To opt-out of Google Analytics relating to your use of our Services you can download
and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.
Do Not Track Signals.
At this time, we do not respond to browser ‘Do Not Track’ signals.
Not Providing Personal Information.
You may choose not to provide personal information to us. However, if you do not provide personal
information, parts of the Services will not be available to you.
Accuracy and Updates to Personal Information
If you have a change to your personal information, you may contact us at
email@example.com to update such information. To the extent that you provide us with current information, we do
our best to keep your information accurate and up-to-date. We will make good faith efforts to
make requested changes in any active database as soon as practicable.
We may use an unaffiliated payment service(s) to allow you to purchase a product or service or
make payments on your account (“Payment Service”). If you wish to make a payment using the
Payment Service, you will be directed to the Payment Service to enter your payment information.
Any information that you provide to a third-party Payment Service will be subject to the applicable
are not responsible for, any such Payment Service’s use of information collected through any
Payment Service. By submitting such information, you grant to the Payment Service the right to
provide such information to third-parties for purposes of facilitating the completion of any
transaction initiated by you or on your behalf.
We use commercially reasonable security technologies and procedures to help protect your
personal information from unauthorized access, use or disclosure. However, no one can
guarantee the complete safety of your information. It is your responsibility to keep your account
information confidential. If you are using a shared computer, you should always log out before
leaving the Services to protect access to your information from subsequent users.
We will retain your information for the period necessary to fulfill the purposes outlined in this
always possible to completely remove or delete all of your information due to technical
constraints, contractual, financial or legal requirements. Remember that even after you cancel
your account, copies of some information from your account may remain viewable in some
circumstances where, for example, you have shared information for collaboration or with social
media or other services. We may also retain backup information related to your account on our
servers for some time after cancelation for record keeping, fraud detection or to comply with
applicable law or our internal security policies.
Data Location and International Transfer and Processing
The Services are hosted and operated in the United States and Germany.
By using the Services or otherwise providing information to us, you understand and consent to having any personal
information transferred to and processed in the United States and Germany.
United States data protection and other relevant laws may not be the same as those in your jurisdiction if you are
located outside of the United States. In certain circumstances law enforcement or regulatory
agencies, courts or security authorities in the United States may be entitled to access your
personal information. If you are a user located outside the United States, please read this privacy
policy with care. All data processing in Germany is subject to all applicable laws and regulations
in Germany and the European Union.
The Services are for a general audience and are not targeted to children. We do not knowingly
collect personal information from anyone under 13 years of age.
Other websites and services to that we link to, through which you access the Services, or share
information from the Services that are not owned or controlled by us are not subject to the terms
parties that support the Service, including by providing advertising or other services, such as
analytics, may use tracking technologies to collect information about your use of the Service or
other third-party services. We do not control these third-party technologies or services and their
use is governed by the privacy policies of third-parties using such technologies. Such third-party’s
Policy will be posted to the Service and/or emailed to the last email address you have given to us
Services or send the email