Privacy Policy

Last Updated September 26, 2023

Welcome to Freeya! This Privacy Policy explains the collection and treatment of your information when you use our Freeya marketplace (“Freeya”), visit our website or online channels (the “Site”), or use other products or services we offer (collectively, our “Services”). Your use of our Services is subject to this Privacy Policy and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. We encourage you to read this Privacy Policy carefully to understand how we collect and use your information.

QUICK SUMMARY

Here is a quick summary of Freeya's privacy practices. We encourage you to read this Privacy Policy in its entirety.

Freeya may collect your Person Information as a Site visitor or a registered Freeya user (“User”)
Freeya is for adults age 18+, not kids.
You consent to this Privacy Policy and our privacy practices by visiting the Site or using our Services in any manner. If you do not agree with this Privacy Policy, do not access or use the Services.
Details of how Freeya collects and uses Personal Information are provided in Section 3.
You can control your Personal Data through your account or by changing your consents or privacy settings. See Section 7 for details.
If we make material changes to how we treat your Personal Information, we will post the revised Privacy Policy on this page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes.
If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@freeya.com.

BY ACCESSING OR USING OUR SERVICES, YOU ACCEPT AND CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF USE.

LET'S DEFINE “PERSONAL INFORMATION”
As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information falls within certain categories, for example:
1. Identifiers (e.g., name, email, telephone number, address, username);
2. Sensitive information (e.g., government ID, health data, precise geolocation, racial/ethnic origin, religious beliefs, contents of messages when we are not the recipient, information about a known child);
3. Legally protected information (e.g., race, citizenship, marital status, sex);
4. Employment-related information (e.g., current or past employment);
5. Non-public educational information;
6. Biometrics (e.g., face/voice prints) and audio, electronic, visual, thermal, or olfactory information;
7. Commercial history (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
8. Internet or other similar activity (e.g., browsing history; content interactions); and
9. Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Please note that not all information about you is Personal Information. Information that is often exempted from privacy law protection includes publicly available information, aggregated information (meaning data summaries or reports with Personal Information removed), and anonymized information that cannot be linked back to an individual.
FREEYA IS NOT FOR KIDS
Freeya is designed for adults, not children. You must be 18 or older to use Freeya or our other Services. We do not knowingly collect Personal Information from anyone under age 18. If we discover that a minor has provided us with Personal Information, we will delete their information from our systems. If you believe we might have any information collected online from a child under 18, or if you become aware of any unauthorized submission of information to, please notify us at privacy@freeya.com.
HOW WE COLLECT AND USE PERSONAL INFORMATION
We may collect your information as a registered Freeya user (“User”) or as a Site visitor so you can use Freeya or other Services you request. In the preceding 12 months, Freeya has collected identifiers, commercial information, and internet activity as described in this section. The Personal Information we collect, use, retain or share is reasonably necessary and proportionate to the purpose for collection or compatible purposes, or for other purposes that we will tell you about. We do this with your consent or other legitimate interest, or as authorized or required by law.
1. Site visits (with consent). If you inquire about Freeya by visiting our Site or contacting us, we will collect your name, email address and other contact information as needed to provide you with the information you request. We collect this information with your consent, and we use it for the purposes stated at the time of collection and to communicate with you or send you marketing information according to your stated communication preferences. We may post User testimonials and comments on our Site upon written notice to you, which may contain Personal Information. You have the right to request removal of such testimonial and/or comment(s) upon receiving our written notice.
2. User registration (with consent). To make Posts or arrange Pick Ups on Freeya, you must first register and create a User Account that includes your first and last name, email address, phone number, payment information (via a PCI-DSS compliant payment processor), and physical address, as well as other identifying information. Users will be asked to verify their email and phone as part of the registration process. If you choose to link your User Account to a third-party account (such as your Google or Facebook account), we will collect and use information from the third-party account based on your permissions and the third-party's practices. We collect this information with your consent and we use it to provide you with Freeya and our other Services.
3. User Posts and messages (with consent). If you make Posts, send a message to arrange Pickups or communicate with other Users, or submit any other content to the Services, we will collect data from your activity including your commercial history, internet and similar activity, and any other Personal Information that you choose to submit. We collect this information with your consent or to achieve our legitimate interest of providing and improving the Services. We use this information for verification purposes, to facilitate your Posts and Pickups, and to provide and monitor use of the Services.
4. Technical data when you use the Services (with a legitimate interest). We may automatically collect technical data, including some Personal Information, from your interactions with the Services; such as: (i) device information (e.g., IP address, operating system, browser type, device ID, VPN); (ii) usage details (e.g., traffic data, search queries, content interactions); (iii) Site visitor data through third-party services such as Google Analytics; or (iv) stored information. We use this data to track usage of the Services, analyze metrics, and assist with support issues that may arise. Like most online services, we use cookies and related technologies as described in our Cookie Notice. We collect this information to achieve our legitimate interest of providing and improving our Services.
In addition to the specific uses described above, we reserve the right to use your Personal Information to (i) protect your privacy and the privacy of others; (ii) comply with a law, regulation, legal process, or order; (iii) monitor your compliance with this Privacy Policy and your agreements with us; (iv) if we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Freeya, or to others; or (v) for any other purpose with your consent. Freeya will not collect additional categories of Personal Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection without first notifying you by updating this Privacy Policy or through other means.
WHEN WE DISCLOSE PERSONAL INFORMATION.
In the preceding 12 months, Freeya has disclosed Personal Information we collect for one or more business purposes to these recipients:
1. Other Users. If you make or respond to a Post, arrange a Pickup, or participate in User-to-User matchmaking, other Users with whom you engage may see Personal Information in your User Account. To access your Personal Information, a User must request access via your Posts and through your User Accounts. Other Users can access any information you share with them by way of direct message or that you publish in any Posts. You consent to these disclosures by participating in these Services features. Be careful what you share in Posts and messages, as other Users may have access to that information and can save it. You are responsible for the information you share with other Users.
2. Our Service Providers. We use service providers like data hosting, analytics, customer support, and communication services to provide our Services and certain features. We may disclose Personal Information to our service providers as needed to perform their contractual obligations to us. The type of information that we provide to a Service Provider will depend on the service that they provide to us. We explicitly require all of our service providers to acknowledge and adhere to our data handling policies and applicable regulations and laws.
3. Law Enforcement. We reserve the right to disclose your Personal Information to law enforcement or other government agencies as permitted or required by law.
4. Other Third Parties. We may disclose your Personal Information to other third parties in certain circumstances as permitted by applicable law, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent. Additionally, Freeya reserves the right to disclose account information to others as necessary to determine if a User has used the Services appropriately or maliciously, such as Posting items using another’s address without their permission.
5. Aggregated and Deidentified Information. Freeya reserves the right to disclose aggregated, anonymized, or deidentified information about any individuals with non- affiliated entities for marketing, advertising, research or other purposes, without restriction.
Freeya only disclose your Personal Information to third parties as described above, with your permission, or as otherwise permitted or required by applicable law.
HOW LONG WE RETAIN PERSONAL INFORMATION.
Freeya retains Personal Information for the period necessary to achieve the purpose for which we collected the information, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). For example, we retain data derived from cookies and other tracking technologies for a reasonable period after the date of collection, which may be a few minutes or several months. If you have opted in to receive marketing communications from Freeya, we will retain your contact information and marketing preferences until you opt out. Other types of data are retained and disposed of according to Freeya company policies. When we have no ongoing legitimate business need for Personal Information, we will securely delete or anonymize it. Personal Information stored in our archives will be securely deleted the next time we access it in the ordinary course of business.
COOKIE NOTICE
Cookies are small text files downloaded and stored on your computer or mobile device when you visit or use an online platform. Cookies help the platform recognize your device, store your preferences, or perform certain functions for the platform. Cookies are generally used for functionality, security, analytics, or advertising. Some cookies are strictly necessary to the function of the website or other platform, while others enable certain features. We use the following cookies on the Services:
- Essential: First-party cookie from Freeya for cookie consent banner functionality
- Analytics: Google Analytics cookies (e.g., _ga, _gcl_au, and _ga_6K61GV0732)
- Advertising: Meta cookies (_fp and _fbp), first-party Freeya cookie (ref)
If you want to opt-out of cookies or change your preferences, you can set your browser to reject all cookies, or to prompt you to accept or reject individual cookies. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly. To opt-out of interest-based advertising by advertisers on our Service visit http://www.aboutads.info/choices/.
YOU CAN CONTROL YOUR DATA ON FREEYA.
You can directly control your Personal Information collected through the Services using these methods:
1. Your Account. You can login to your User Account to access or update your Personal Information, adjust your privacy settings, or submit a deletion request.
2. Email Communications. If you provide us with your email address, we may send you informational or support emails or, if you opt-in, marketing emails about our Services. If you do not wish to receive these emails, you can change your preferences via the links provided in the emails or by sending a request to privacy@freeya.com to be removed from our email list. Please note, however, you cannot opt out of emails relating to your User Account, transactions you initiate, or changes to our Terms of Use, this Privacy Policy, or other policies or notices that may affect your access to and use of the Services.
3. Texting. If you provide us with your wireless phone number, you consent to Freeya sending you informational or service text messages. For all text messages, the number of texts you receive will depend on the Services you use and the information you request from us. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
4. Block Location Tracking. You can stop all collection of information by an application by uninstalling it. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an application by uninstalling the application or withdrawing your consent through your device settings. You will lose some functionality of the Services if you block location tracking.
5. Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
6. Privacy Requests. If you wish to exercise your privacy rights beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please submit a request to privacy@freeya.com. We can only fulfill a request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We endeavor to respond to privacy requests as required by the law of your jurisdiction, subject to statutory exceptions and limitations. We do not charge a fee to respond to a request unless we have legal grounds to do so. If we determine that your request warrants a fee, we will tell you why and provide you with an estimate before completing your request.
PRIVACY RIGHTS
Depending on where you live or are located, you may have certain rights over your Personal Information that we collect and retain. Freeya will facilitate your exercise of those rights as described in this section. Some consumer privacy laws may not apply to you or your access to or use of the Services, in which case these notices are offered as a courtesy.
1. U.S. Privacy Rights. In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing with general consumer privacy rights. This section provides informational notices for state privacy laws applicable to residents of California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states that require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Residents of states offering privacy protections (each a "Consumer") may have some or all of the following rights:
  1. Right to Correct. You have the right to request that we correct inaccurate Personal Information about you on our systems. If you become aware that the Personal Information that we hold about you is incorrect or if your information changes, please update your account details or inform us and we will update our records.
  2. No Sale or Sharing of Personal Information. We do not sell your Personal Information or share your Personal information with third parties for cross- contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.
  3. Limited Use and Disclosure of Sensitive Personal Information. We do not seek to collect sensitive Personal Information about any individual. In no case will we use or disclose any sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to limit use and disclosure of sensitive Personal Information.
  4. Right to Opt-Out of Profiling. The Services may process your Personal Information to curate the content you see or notify you of Posts that we believe will interest you. You can opt-out of this type of processing by adjusting your User Account settings or contacting privacy@freeya.com.
  5. Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. We may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. You can delete some of your Personal Information through your account. If you ask us to delete your Personal Information, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
  6. Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Information, such as: (1) the categories of Personal Information we have collected about you; (2) the categories of sources for the Personal Information we have collected about you; (3) our business purpose for collecting or selling that Personal Information; (4) the categories of third parties with whom we share that Personal Information; and (5) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating: (A) sales, identifying the Personal Information categories that each category of recipient purchased; and (B) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Under the CCPA, we are only required to respond with respect to activities over the past 12 months and only to two disclosure requests within a 12-month period.
  7. Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you (also called a data portability request). If you submit an access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that we are prohibited by law from disclosing copies of certain pieces of Personal Information because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. In some cases, we are only required by law to respond to access requests covering the prior 12 months and only two requests within a 12-month period.
  8. Right to Nondiscrimination. We will not discriminate against you for exercising any of your legal rights. Unless permitted by law, we will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services; (3) provide you a different level or quality of goods or services; or (4) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (5) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under privacy law.
  9. Right to Disclosure of Marketing Information. California's Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
  Consumers may take many of the actions described above by logging into their account and changing their profile information or settings or by submitting a request to privacy@freeya.com.
2. Canadian Privacy Rights. This section provides the disclosures and notices required under Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”) and solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The rights afforded under PIPEDA are described below.
  1. Right to know why we collect, use, and distribute the Personal Information we process. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
  2. Right to expect us to collect, use, or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Policy and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at privacy@freeya.com.
  3. Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
  4. Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. We may not be able to provide access to some or all of the Personal Information you request if limited by law or potential infringement of another’s privacy rights. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.
  Canadian Consumers may exercise these rights by submitting a privacy request to privacy@freeya.com.
CROSS-BORDER DATA TRANSFERS
Freeya owns and operates the Services in the United States. We do not warrant that the Services are appropriate or authorized for use in any other country. If you use the Services from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction.
We employ legally valid transfer mechanisms for all cross-border transfers of Personal Information. To the extent that we are deemed to transfer Personal Information from the European Economic Area to other jurisdictions, we do so on the legal basis that such transfer is necessary to provide you with the Services you have chosen to use.
You are responsible for determining whether this Privacy Policy and our Services comply with the laws that apply to you. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
OUR DATA SECURITY
Freeya implements reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. Procedures and practices by which we protect your Personal Information include, but are not limited to, encryption of information using secure socket layer technology (SSL), deletion and de-identification of data, secure messaging services, a designated Freeya security coordinator, and periodic internal audits. Our employees, contractors, and agents responsible for handling privacy inquiries are informed of applicable legal requirements and we restrict access to those who need that information to process it.
Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. The security of your Personal Information also depends on how you use the Services. We encourage you to take steps to safeguard your Personal Information by signing off your device after use and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.
OTHER WEBSITES AND SERVICES
The Services may include links to third-party websites or platforms for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third parties. Freeya is not responsible for the privacy practices of any third party, and your access to and use of third-party websites is governed by the privacy notices of those websites.