Freeverse S.L. (Freeverse) Privacy Statement
Freeverse is absolutely committed to respecting and protecting your data whilst it is in our care. We collect your personal information because it helps us to understand your needs and guides the way in which we interact and communicate with you about our products and services now and in the future. We have strict policies and procedures in place to protect your data when you send it to us; when we process it in order to provide you with the services you have requested; or, where you have given us your permission to do so, to send you information that we think you’ll find interesting, and thereafter when we store your data on our secure servers.
Freeverse rely upon four of these lawful ways to collect, use, store and process personal data: Consent, Contractual; Legitimate Interests and Legal Obligations.
To perform our contractual obligations to you
We process your information to perform our contractual obligations to you when we use your information to provide you with the Services. For example, when you sign up for our services, we process your contact information as necessary to confirm the subscription and we process your contact information and other details to provide you with support services in regard to your subscription.
To pursue our legitimate interests
We process your information to meet our legitimate interests when we use your information to provide you with the Services to communicate with you and for our advertising, events and marketing purposes. In such cases we have balanced our interests with your interests and believe that these activities will not have a negative impact on your privacy rights. You can withdraw your consent at any time, by emailing firstname.lastname@example.org.
To comply with our legal obligations
We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.
With your consent
We obtain your consent to process your information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by emailing email@example.com.
Freeverse collects Personal Data in a number of ways, such as when you provide details at an event or when you interact with us via a website, mobile app or other digital services (“Services”). This Personal Data could include:
You may give us information about other people, such as the name and email of a contact if you are attending an event or the name and address of a gift subscription recipient. Please ensure that you are authorised or have the person’s permission to do so.
We hold your personal data on our secure systems, mainly based in Spain and the European Economic Area (EEA). Our staff are trained in data security, and our staff policies and procedures help our staff to understand what is required of them under their obligations to us, and also their responsibilities under GDPR and other privacy legislation.
When we ask another organisation to provide a service for us, we ensure that they have appropriate security measures in place.
We may collect your details when you register on one of our websites; sign-up to our service; correspond with us by phone, e-mail or otherwise; participate in discussion boards or other social media functions on our website; enter a competition or promotion; apply for a job.
We will always be transparent about how we plan to use your data so that you have the choice whether or not to give it to us. We respect your preferences and will do our best to make sure that we keep our promises.
We may need to authenticate your identity to provide you with access to subscriber-only services.
Our iPad, Android and other “apps” may collect user data, which we use to learn about our readers and improve our apps.
To understand how our “apps” are used we may use the service Google Analytics to provide us with anonymous statistical information about your use of our app(s).
Fulfilment of a service
We will use your personal data when fulfilling a product or service that you have requested. For example, signing up for the Freeverse Marketplace.
We will only send you direct marketing when you have either provided consent for example by ticking a box or where we believe we can demonstrate a legitimate interest and have balanced this with your interests and privacy. You can opt out of receiving direct marketing at any time by or emailing firstname.lastname@example.org.
Please take care when using social networking sites to which we may invite you to join that you do not disclose anything that you might later wish to retract.
There are certain times when we may have a legal obligation to disclose your data in good faith where it is required by law or to respond to subpoenas or warrants served on us, or where we have a requirement to protect or defend the rights of Freeverse or any users of our servers. We will always ensure that those requesting the information have the legal right to do so.
You have the ability to accept or decline cookies, when you use the website for the first time via “see all options” link on the “pop up” banner, but please be aware that for some parts of our sites to work, you will need to accept cookies.
If you receive a marketing email from one of our brands, you may choose to opt-out from receiving future emails by sending an email to email@example.com.
We do not knowingly collect personal information from children under the age of 16 for marketing purposes.
Our servers are situated in the EEA and when you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 which stem from European Directives 95/46/EC and 2002/58/EC respectively. If you are not in agreement please do not add your personal details on the website.
Under GDPR, you have a number of rights, which are aimed at giving you control about how your personal data is used by us.
Access your personal data
You have the right to see what information we hold about you and the purposes for which we are using it. This is known as a Subject Access Request. In responding to such a request, we may ask for proof of your identity, to ensure that we do not send you personal data to another person. We will respond to any requests as soon as possible, but at least within 30 days.
Please email firstname.lastname@example.org to make a Subject Access Request.
Amend your personal data
You may ask us to make any changes that you consider necessary to make the information accurate, please let us know and we will rectify this as soon as possible. Please email email@example.com with your request.
We will require that you satisfactorily identify yourself to demonstrate your entitlement to view this data.
Delete your personal data
If you wish for your personal data to be deleted we will review any request on a case-by-case basis. We will respond to you as soon as possible, at least within 30 days of receiving your request.
Object to the processing of your personal data
You have the right to object to the processing of your personal data, for reasons relating to your particular situation. In this case, Freeverse will cease the processing of such data, except for compelling legitimate reasons, or for the submission, exercise or defence of claims.
Limit the processing of your personal data
Subject to certain conditions, you may request the limitation of the processing of your data, in which case Freeverse may only process them, with the exception of their storage, with your consent, for the exercise or defence of claims, for the protection of the rights of third parties or for reasons of public interest.
You have the right to receive or, where appropriate, to request that Freeverse provide your personal data to third parties in a structured, commonly used and machine-readable format, provided that such processing is based on your consent and is carried out by automated means.
We hold personal data for different purposes and the length of time we keep your information will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data:
Once that purpose has been fulfilled, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.
Complaints will be dealt and responded to within 30 days. If you are not satisfied with the response you should refer your complaint to the SDPA www.aepd.es.