Privacy Policy
Last Updated on 28.01.2025
Introduction
Thank you for visiting Freedx. Your privacy is important to us, and we want you to feel comfortable with how we collect, use and share your personal information. Freedx (FREEDX, S.A. DE C.V., Registration number: 11 of book 4900, Tax identification number: 0623-120724-114-1, Address: Avenida La Revolución, Plaza Presidente, Local 12, Colonia San Benito, San Salvador, San Salvador Centro, El Salvador) together with the various parties it works with to provide you with its products and services are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data which we will collect from you, or collected about you, on freedx.com website or on our mobile application (collectively, the “Freedx Platform”) or when you communicate with us by our online help chat function, email, telephone or post will be processed. This policy also explains when and why your data is collected, how it is used and disclosed and how it is kept secure.
The products and services referred to in this policy relate to those offered by Freedx and any other third parties we work with to offer our suite of services (together, the “Services”).
Please read the following carefully to understand our views and practices regarding your personal data and how it will be treated.
Freedx will act as a data controller of your personal data which: -
- You provide to us (see ‘When you create a Freedx account below) and;
- Which we may automatically collect about you – for example, details of your browser and operating system, the website from which you visit our site, the pages that you visit on our site, the date of your visit, and, for security reasons such as to identify attacks on our site, the Internet protocol (IP) address assigned to you by your internet service, location information, etc. We may use Google Analytics to collect tracking information about you.
This means that at Freedx, we are responsible for deciding how we hold and use personal data about you, and we are required to notify you about what data we collect and its usage in this policy.
Information we collect about you and how it will be used
When you create a Freedx account
When you sign up for an account on the Freedx Platform, we will need to collect (and in some cases store) some or all of the following details about you:
- Personal identification details such as name, residential addresses (current), date of birth, email address, telephone number(s), tax number (if applicable), ID document such as passport, driving licence or ID card, image or photo of you;
- Corporate details such as legal name, registration details, tax number (if applicable), address, business description, and beneficial owner information;
- Details about your transactions on the Freedx Platform;
- Financial details such as credit/debit card numbers and bank account information;
- Information required under the applicable laws;
Other details such as IP address and geolocation.
We will use this information for the purposes of processing your application. If your application is approved, we will also use this information to create and manage your Freedx account and provide the Services you have requested. If you have consented, we may also provide you with information about our products and services that may be of interest to you, from ourselves and third parties, and future announcements by email.
You will not be able to create a Freedx account or order Services from us without providing this information.
Ensuring the lawful use of your personal data
Your personal data will only be used by us or the parties we work with in order to provide you with the Services we are lawfully able to offer. The purposes for which we will use your personal data include:
- Where it is necessary for the performance of the contract with you or to take steps to enter into it. For example, when we need to verify your identity, to provide you with Services, communicating with you, to provide you with updates on the status of your account, complaints handling, and dealing & notifying you of any changes to this statement.
- It is necessary for our legitimate interests or that of a third party. This includes:
- to enhance and personalise your visitor experience;
- to identify you when you contact us and to correspond and communicate with you;
- for market research in order to continually improve the Services that we offer and deliver to you;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a client or visitor;
- creating a profile of you, which enables us to identify and personalise what products and services to offer to you for marketing purposes;
- to administer our site, for website analysis and for internal operations, including troubleshooting, testing, statistical purposes;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for the prevention of fraud and other criminal activities;
- to protect our contractual or other legal rights;
- for general administration including managing your queries and to send service messages to you.
- It is necessary for compliance with a legal obligation. This includes, but not limited to, when you exercise your legal rights under data protection law, to verify your identity, for the establishment and defence of our legal rights and for compliance with our legal and regulatory responsibilities.
- You have given us your consent to use your personal data in certain ways, including when you request that we disclose it to a third party and for direct marketing communications (by us and the third parties named when we asked for your consent).
- In order to process your Freedx account creation we may need to perform Fraud and money laundering checks before and whilst we continue to provide Services to you. This may involve sharing your personal data with fraud prevention agencies who will also process your personal data, but only on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
You have the right at any time to ask us, or the third parties we work with, to stop contacting you or passing your details to others for marketing purposes. Please contact us for further information.
Automated decisions
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:
- our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or
- you appear to have deliberately hidden your true identity.
You have rights in relation to automated decision-making: if you want to know more, please contact us using the details below.
Consequences of processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.
Other than the automated processing set out above, we shall not carry out solely automated decision-making using your personal data.
When you contact us
When you contact us, we will need to collect personal data about you to verify your identity before we disclose any information to you for data security purposes. We will be unable to deal with your query unless you provide the information we request. We may also collect any other personal data you choose to provide to us when communicating with us. We will only use that personal data for the purposes of dealing with your enquiry.
The information we receive from other sources
We are also working closely with third parties (including, for example, identity verification agencies, marketing agencies and fraud prevention agencies) and we may receive information about you from them for the purposes of identity verification, marketing and fraud prevention.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will usually notify you and we will explain the legal basis which allows us to do so.
Disclosures of your information
We may disclose your information to:
- Law enforcement and fraud prevention agencies, identity verification services and other organisations for the purposes of preventing fraud and money laundering;
- Our Group companies and third parties, for the purposes of processing transactions and providing Services that you have requested;
- Courts as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations;
- Third parties acting on our behalf, such as service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. These parties may include back-up and server hosting providers, IT software and maintenance providers, third parties that provide income verification services and affordability checks, claims management companies, communication fulfilment services, marketing research organisations and Google Analytics;
- Other third parties, with your consent, who may contact you by email to provide you with information about their products and services which may be of interest to you;
- In the event that we sell or buy any business or assets, to the prospective seller or buyer of such business or assets;
- A third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Freedx, our clients or others.
Protecting your information
We protect your data by using reasonable physical, technical, and administrative security measures to ensure information security, including encryption of the Freedx Platform communications; required two-factor authentication; periodic review of our personal data collection, storage, and processing practices; and restricted access to your personal data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.
For users who are located in the EEA or other locations subject to EU data protection laws, we additionally adhere to relevant and applicable provisions of the General Data Protection Regulation (EU) 2016/679 (GDPR).
Storing your data
You acknowledge that we store and process your personal data in multiple locations in the world where our Group companies or service providers are located, and we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable regulations.
Use of Cookies
Cookies are small text files that are placed on your device (e.g. computer, mobile device) when you visit a website and give permission for that site to recognise your device. Cookies store information about a user’s visit, which may include the content viewed, language preference, time and duration of each visit to the website.
Cookies are widely used in order to make websites work more efficiently, such as letting you navigate between pages efficiently, remembering your preferences, as well as providing information to the website owner.
We may use cookies to enhance your experience on our website, identify users, remember user preferences, as well as to collect and analyze website usage data related to users and patterns.
Future changes
Any changes we make to our policy will be made available on the Freedx Platform and, where appropriate, notified to you by e-mail. Please check for updates from time to time.
Retention of your Data
We will retain your personal data for as long as you continue to use our Services. Thereafter, we may retain your information for an additional period as is permitted or required under applicable laws.
Your rights
Data protection laws provide you with the following rights to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below). However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you;
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- request a copy of your personal data which you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer it, or to require us to transfer it directly, to another controller.
- object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
If you are unhappy about how your personal data has been used, please refer to our complaints procedure which is available by contacting us.
Contacting us
If you have any questions about this policy, you can contact us in the following ways:
By post at:
Av La Revolucion, Apto. Local 12, Colonia San Benito, Distrito San Salvador, Municipio De San Salvador Centro, Departamento De San Salvador
By email at: support@freedx.com
This policy was last updated on 28.01.2025