PRIVACY POLICY

1.      INTRODUCTION

This Privacy Policy governs the access and use of both the "FREEDOM" application (the "Application") and the Platform accessible through it (hereinafter, all referred to as the "Platform"), through which users are granted access to a technology that allows them to receive news from the user political party of the application to which they are affiliated (provided that the said party is qualified as a "Participating Party"), communicate with its leaders, participate in debates, initiatives and polls of the party, share opinions on the Platform or through other social networks to the extent that these options are available (YouTube, WhatsApp, Facebook, etc.), and in general, allow an online relationship between the Participating Party and the users affiliated thereto (hereinafter all referred to as the "Services" or individually the "Service ").

The Platforms through which the Services are provided are compatible with the main operating systems in the market and are owned by Freedom Social Technology Worldwide, LLC. (hereinafter, "FREEDOM"), a company registered with the Corporations Division, Secretary of State, of the State of Delaware, at the office located at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, on 5 December 2017, under the File number 6647340, as evidenced by the Certificate of Incorporation, and with United States tax identification number (US federal tax identification number) 82-3631710. To contact FREEDOM, the following communication channels are made available to the User, including the contact details of their data protection delegate:

-          E-mail of the data protection delegate: privacy@freedom.technology

-          Postal address of the data protection delegate: Via Milazzo 15, 21052 Busto Arsizio. Italia.

Not being established in the territory of the European Union, FREEDOM has appointed a representative within the European Union for the purposes of data protection in accordance with the provisions of the applicable legislation. The identification and contact data of said representative are:

-           Identity: Gianluca Favro

-        E-mail: gianluca@freedom.technology

-           Phone: +39 347 631 8553

-          Postal address: Via Milazzo 15, 21052 Busto Arsizio. Italia.

Although FREEDOM is not a commercial platform, given the fact that we need a registry to be able to save the recordings, have a file, etc., we need to give all of that a serious legal coverage that guarantees our users the treatment of their data. This Privacy Policy is applicable to all Personal Data that for the use of the Services you may have provided or which we may have collected.

 

 

2.        COLLECTION, TREATMENT AND PURPOSE

In order to register for the Service, you must previously provide certain personal data through the relevant forms INCLUDING POLITICAL AFFILIATION DATA, WITHOUT WHICH YOU MAY NOT BE REGISTERED AS A USER. THEREFORE, UPON REGISTERING AS A USER, YOU WILL BE GIVING YOUR CONSENT TO THE PROCESSING OF SUCH IDENTIFICATION, CONTACT AND POLITICAL AFFILIATION DATA, AS WELL AS THE REST OF THE DATA THAT WE HANDLE, AND SUCH CONSENT MAY BE REVOKED AT ANY TIME THROUGH A REQUEST AS A USER THAT YOU MAY SEND TO THE FOLLOWING E-MAIL ADDRESS: privacy@freedom.technology, or you may also make an application from the app in the user profile to "report a problem or suggestion". Right there you may request the cancellation of the application and we will respond within a reasonable time. If there is any error in the data collection, it will be indicated by red asterisks, so you may modify them conveniently. In this regard, you must declare that your data are accurate and current. In addition, throughout our relationship with you, we will collect data regarding the communications or interactions you perform through the platform, as well as your use thereof. The handling of your data will include those that you necessarily provide during the registration process (including identification, contact and political affiliation data), without which it will be impossible to proceed with the registration, as well as the transactional and/or interaction data generated through your activity on the platform (such as your publications and/or actions thereon), which will be captured through the Platform.

The file in which the data collected are stored, both during the registration in the Service and by reason of the use thereof, is owned by FREEDOM and is intended for (i) handling the Services Platform and to communicate the contents generated thereon between both Users (including your Participating Party of affiliation) and through social networks, as well as (ii) making reports and studies about the Users (which in any case will not include personal data, having been duly anonymized), and (iii) implementing promotional actions of services or related to your user profile (such as, where appropriate, the offering of a payment channel for the payment of membership fees and/or for making donations in favor of the party to which you are affiliated or of which you are sympathetic), actions that we can direct to you by any means, including e-mails of a commercial nature. User profiling will not be made nor will they be submitted to automated decisions. The legal basis that will allow such actions is the consent that you, as a User, have granted when registering on the Platform, which consent may be revoked at any time in the manner described above.

At any time, you may indicate that you do not wish to continue receiving our commercial communications by ordinary mail by contacting us at this e-mail address support@freedom.technology or by pressing the button titled "stop receiving communications" that will be included in all commercial communications.

The subscription to our Services may entail the use of your Personal Data to make personalized advertising available to you concerning our products and services (described above) through e-mails, SMS's, APP push notifications, or other electronic means owned by us by third-party collaborators.

Should through any functionality of the Service you provide us with information from a third person, you guarantee that you have obtained the consent of that person and that you have informed him/her and/or given him/her the opportunity to inquire about the treatment we will make of your personal data in accordance with the provisions of this policy.

Lastly, you declare that all Personal Data included in the recordings or in those contents or works that you prepare have been collected with the consent of the participating individuals.

The personal data we may obtain from you will be handled only for the duration of our service relationship (until you unsubscribe from the Platform) and, further, only whilst (i) we are required by law to retain the data, and/or (ii) they have not prescribed the actions for which the data might be relevant (mainly, contractual actions derived from our relationship with you, currently subject to presumptive men of five years, in accordance with the provisions of Article 1164 of the Civil Code).

3.        INFORMATION ASSIGNMENT AND/OR COMMUNICATION

By using this application, you agree that we may share the encrypted information we collect, including your e-mail address, IP address, and/or other device identifiers, with our partners and with the Participants Parties for the handling of the Service and the affiliate relationship you have therewith.

We may assign your Personal Data to the Participant Party on the application to which you are affiliated so that you may establish your connexion with the Platform, manage your affiliate relationship, as well as its communication with you and publish the contents you may contribute to it. THIS TREATMENT WILL BE IN COMPLIANCE WITH THE PRIVACY POLICY THAT THE PARTICIPANT PARTY MAY SHOWS IN ITS TAB. ALSO, THE FACILITATED DATA MAY BE COMMUNICATED TO OTHER COMPANIES OF THE SAME BUSINESS GROUP TO WHICH FREEDOM BELONGS FOR THE SAME PURPOSES FOR WHICH THE COMPANY IS ENABLED TO HANDLE THE DATA. WITHOUT PREJUDICE TO THE PREVIOUS COMMUNICATION WITH THE POLITICAL PARTIES TO WHICH YOU ARE AFFILIATED AND/OR WITH WHICH YOU SYMPATHISE, FREEDOM WILL NOT GIVE THE DATA TO THIRD PARTY COMPANIES FOREIGN TO THE SAME BUSINESS GROUP TO WHICH FREEDOM BELONGS, UNLESS SUCH COMMUNICATION IS MADE IN A DISSOCIATED MANNER, SO THAT THE USER'S IDENTITY REMAINS FULLY ANONYMOUS. ALSO, BY USING THE SERVICE, YOU ACCEPT THAT SOME OF THE FACILITATED DATA, WHERE SO DERIVED FROM THE NATURE OF THE CORRESPONDING SERVICE, WILL BE MADE AVAILABLE TO OTHER USERS OR TO THE GENERAL PUBLIC. YOU ACKNOWLEDGE AND AGREE THAT ANY QUESTION, COMMENT, SUGGESTION, IDEA, FEEDBACK, OR OTHER INFORMATION CONCERNING THE APPLICATION OR THE SERVICE (THE "REMITTED INFORMATION ") THAT YOU SEND TO THE COMPANY WILL NOT BE OF A CONFIDENTIAL NATURE AND WILL BE USED BY FREEDOM; that jointly with the Participating Party it will have exclusive rights, including all intellectual property rights, and IT may disclose and use the aforementioned Information without restriction.

Also, we may share your data and information to third parties who provide support services to us, such means of payment or financial entities, anti-fraud entities, providers of technological services and/or analysis of the transactions carried out through the web, and/or applications in order to offer users sufficient guarantees in operations commercial, etc., with these always acting as in charge of the handling. Their authorization includes those cases where for service efficiency, providers may be located in the United States of America or other countries or territories located outside the European Economic Area that do not provide a level of data protection comparable to that of your country or, where appropriate, to that of the European Union. In these cases, we shall always mainly apply appropriate safeguards and implement, jointly with the recipients of model data contracts approved by the European Union, such as the one provided for in the Commission Decision of 5 February 2010 concerning the model contractual clauses for the transfer of personal data to those responsible for processing established in third countries, pursuant to Directive 95/46/EC of the European Parliament and of the Council.

 

4.        LINKS

Your personal data will be processed by FREEDOM but also by the political party to which you are affiliated (the "Participating Party").

The Service may include, show, or display links to other web pages for your greater convenience and information. These web pages may operate independently of us. It is possible that these pages with links may have their own privacy policies and we strongly recommend you to read then when you visit them. To the extent that any website with links that you visit is not our property nor under our control, we shall not be responsible for the contents of such websites, or their use or privacy practices.

In this Service you may choose certain functions that operate over Personal Data that we share with other entities or websites (as, for example, "share" on Facebook). These functions, which include from social networking tools to geographic location tools, are operated by third parties that are not associated with us. These third parties may utilise personal information in accordance with their own privacy policies. These third parties are identified in the web pages where these functions are offered. We strongly recommend that you review the privacy policies of these third parties if you are going to use the corresponding functions.

 

5.      YOUR RIGHTS

You have the possibility to exercise, in accordance with the provisions of the said regulations, the rights to access, rectification, deletion, limitation, portability, opposition, and not being the subject of a decision based solely on automated processing, including the preparation of profiles, by sending us for this purpose an e-mail to the address provided above for the Data Protection Delegate, providing a photocopy of the DNI or alternative documentation that proves your identity.

Also, you may choose to stop receiving commercial and promotional communications by regular mail by contacting us as indicated above.

Lastly, we inform you that in case you consider that we do not fulfil our obligations concerning data protection, you have the right to go to the appropriate supervisory authority (which in Spain is the Agencia Española de Protección de Datos [Spanish Data Protection Agency]) and file with it the complaints and/or actions that you may deem appropriate.

 

6.      DATA TRANSFERS

We might transfer your Personal Data to countries other than the country in which the information was originally collected. Thus, we will make international transfers [to the] United States in order to manage the Service and our contractual relationship with you, so that either we or collaborators or service providers hired by us can perform behavioral advertising analyses and marketing and promotional campaigns.

We will comply with the applicable legal requirements by providing adequate protection for the transfer of personal information to countries located outside the European Union. In these cases, we shall always apply the appropriate guarantees and, mainly, we shall implement, jointly with the recipients of the data, model contracts approved by the European Union, such as the one referred to in the Commission Decision of 5 February 2010, regarding the model contractual clauses for the transfer of personal data to those responsible for processing that are established in third countries, in accordance with Directive 95/46/EC of the European Parliament and of the Council.

 

7.       SECURITY MEASURES

We are committed to the fulfilment of our confidentiality obligation regarding Personal Data to our duty to keep them, even after the contractual relationship has been terminated (in accordance with the applicable law) by adopting the security measures imposed by current legislation and in accordance with the state of technology in order to avoid their alteration, loss, handling, or unauthorized access.

We guarantee that we have adopted the appropriate security measures in our facilities, systems, and files, as well as the confidential treatment of Personal Data in accordance with applicable legislation.

 

8.      UPDATES OF OUR PRIVACY POLICY

This Policy may be updated periodically upon prior notice sent sufficiently in advance to reflect any changes in our practices on personal information. We will post a prominent notice advising you of any significant changes in our Policy. Each installation or update that you make of any of the applications that are part of the Service will imply acceptance of the new Privacy Policy.

 

9.      HOW TO GET IN TOUCH WITH US

You may contact us if you have any doubt or queries or if you want to be entitled to exercise the rights that your legislation grants you with respect to data protection by sending a signed brief to the attention the "Data Protection Delegate" to the address or to the e-mail address indicated above for these purposes.