Privacy policy

Freeads ("we", "us", "our"), powered by ABT Solutions Ltd., is dedicated to safeguarding and respecting your privacy.

This privacy policy ("Privacy Policy"), along with any other referenced documents, outlines how we collect and process your personal data as a data controller when you utilize our website or services.

Please carefully read the following to comprehend our perspectives and practices concerning your personal data and how we will handle it. By accessing Freeadsinus.com (the "Site") or using our services or apps located at freeadsinus.com, you acknowledge and consent to the practices described in this Privacy Policy.

Please note:

This Privacy Policy does not apply to any data you provide to us when we process personal data on your behalf as your data processor, such as when we handle customer data within the cloud service we offer you as a BTB service provider.

Data controller

For the purposes of Data Protection Law, which includes EU and UK data protection laws, as well as any relevant national implementing laws, regulations, and secondary legislation pertaining to the processing of personal data, the data controller is ABT Solutions Ltd. located at Strathmore 53 Bowleaze Coveaway, Preston, Weymouth, Dorset, DT3 6PL, United Kingdom.

Legal basis for processing

We will utilize your personal data only when permitted by law. The most common instances in which we will use your personal data are as follows:

• To fulfil our contractual obligations to you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To comply with a legal obligation.

If we process your personal data for any other purposes, we will seek your prior consent or ensure that our partners obtain such consent.

Personal data we may collect about you

We may collect and process personal data about you, which refers to any information that can identify you as an individual. This does not include data where your identity has been removed (anonymous data). We collect, use, store, and transfer various types of personal data about you, which we have categorized as follows:

Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data: includes billing address, delivery address, email address and telephone numbers, company name, website.

Financial Data: includes bank account, VAT number and payment card details.

Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or the Services.

Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data: includes information about how you use our Site and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site and Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data: We also collect, use and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

In situations where we are required by law or have a contractual obligation to collect personal data from you, and you fail to provide such data when requested, we may be unable to fulfill the contract we have with you or are attempting to enter into (for instance, to provide you with goods or services). If this occurs, we may need to cancel a product or service you have with us. However, we will notify you in advance if such a situation arises.

How is personal data collected

We employ various methods to gather data from you, including:

Direct Interactions. When you fill out forms, correspond with us through various channels (such as post, phone, email), or engage in other forms of communication, you may provide us with your Identity, Contact, and Financial Data. This includes personal information shared during the registration process, subscription to our services, account creation, marketing requests, product searches, order placements, participation in discussion boards or social media functions, competition entries, surveys, attendance at conferences or webinars, feedback submission, and when reporting issues with our site or services.

Purchases: If you make purchases on our site or within our services, or register for events or webinars, we may require your Identity, Contact, Financial, and Transaction Data.

Community: If you register for an online community provided by us, we may ask for your Identity, Contact, Profile, and Technical Data.

Automated Technologies or Interactions. When you interact with our services, websites, or emails, we automatically collect Technical Information about your device, browsing actions, patterns, Location Data, and Usage Data. This data is gathered through the use of cookies, server logs, web beacons, pixels, and similar technologies. Additionally, we may receive Technical Data and Location Data about you when you visit other websites that employ our cookies. For further details, please refer to the Cookie section below.

Personal data we receive from other sources

We maintain close partnerships with third parties, which may include business partners, sub-contractors involved in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies. Through these collaborations, we may receive the following personal data about you:

Technical Data: We may obtain Technical Data from analytics providers, advertising networks, and search information providers, such as Google and Hotjar.

Contact, Transaction and Financial Data: Providers of technical, payment, and delivery services, such as Stripe, may supply us with Contact, Transaction, and Financial Data.

Identity and Contact Data: Providers of chat/communication services with customers, including email services like Zendesk, may provide us with Identity and Contact Data.

Email Communications and Contact Data: Providers of email communication services, such as Sendgrid and SendinBlue, may furnish us with Email Communications and Contact Data.

Personal data we collect from other sources

We obtain personal data about you from publicly available sources as well. This information may be combined with the personal data you provide to us. The purpose of collecting this data is to update, enhance, and analyze our records, identify new customers, and deliver more personalized advertising and services that may be of interest to you. Additionally, we utilize this data for targeted advertising, delivering relevant email content, promoting events, conducting profiling activities, verifying Contact Data, and determining eligibility. The personal data we collect from publicly available sources includes:

Identity and Contact Data: We may gather Identity and Contact Data from publicly available sources such as Companies House.

Identity, Contact and Profile Data: Personal data published about you on social media platforms such as LinkedIn, Facebook, Twitter, etc., falls under this category.

Cookies

We utilize cookies on our Site and in our Services to differentiate you from other users. This distinction aids us in providing you with a seamless browsing experience on our Site and enables us to enhance the functionality of the Site and Services for your benefit.

What are cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Site. Cookies can be "persistent" or "session" cookies.

We use persistent cookies and session cookies.

Persistent Cookies

A persistent cookie is stored on a user's device in between browser sessions which allows the preferences or actions of a user across the Site (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future logins to the Site or Services.

Session Cookies

A session cookie allows the Site or Services to link your actions during a browser session. We use session cookies to enable certain features of the Site or Services, to better understand how you interact with the Site or Services and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site or Services and then close your browser.

Uses made of personal data

Below, in a table format, we have provided a comprehensive description of how we intend to utilize your personal data and the legal bases on which we rely. In cases where applicable, we have also indicated our legitimate interests. Please note that depending on the specific purpose for which we use your data, we may process it based on more than one lawful ground. If you require information about the specific legal basis we rely on for processing your personal data when multiple grounds are mentioned in the table below, please feel free to contact us.

Purpose/Activity	Type of data	Lawful basis for processing
Register you as a new customer.	Identity, Contact	Performance of a contract with you.
Process and deliver your order including: Manage payments, fees and charges, Collect and recover money owed to us.	Identity, Contact, Financial, Transaction, Marketing and Communications	Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).
Manage our relationship with you which will include: Notifying you about changes to our terms, this Privacy Policy, the Site or Services, Asking you to leave a review or take a survey	Identity, Contact, Profile, Marketing and Communications	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services).
Enable you to partake in a prize draw, competition or complete a survey	Identity, Contact, Profile, Usage, Marketing and Communications	Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
Administer and protect our business and this Site (including troubleshooting, data analysis, testing, systems maintenance , support, updates, reporting and hosting of data).	Identity, Contact, Technical	Necessary for our legitimate interests (for running our business , provisions of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation group restructuring exercise). Necessary to comply with a legal obligation.
Deliver relevant Site and Services content and advertisements to you and measure or understand the effectiveness the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Use data analytics to improve our Site and Services , marketing , customer relationships and experiences.	Technical, Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Make suggestions and recommendations to you about goods or services that may be of interest to you.	Identity, Contact, Technical, Usage, Profile, Marketing and Communications	Necessary for our legitimate interests (to develop our Services and grow our business)

Disclosure of your personal data

Personal data we share with third parties

We may disclose your personal data to the following third parties for the purposes outlined in the table above:

• Any member of our group, including subsidiaries and ultimate holding company, as defined in section 1159 of the UK Companies Act 2006.
• Business partners, suppliers, and subcontractors who assist us in providing services such as IT and system administration, email communications, hosting, backup, credit card processing, research, development, marketing, and customer support. This includes providers such as AWS, Digital Ocean, Cloudways, Sendgrid, SendinBlue, Segment, Zendesk, Namecheap, and Stripe.
• Professional advisors who provide consultancy, banking, legal, insurance, and accounting services to us in relation to the Site or Services. This includes lawyers, bankers, auditors, and insurers.
• Tax authorities, regulators, and other authorities when reporting of processing activities is required in specific circumstances.
• Advertisers and advertising networks that require data to deliver relevant advertisements to you and others. Please note that we do not disclose personal data about identifiable individuals to advertisers. However, we may provide them with Aggregated Data about our users. We may also use such Aggregated Data to assist advertisers in reaching their desired target audience.
• Analytics and search engine providers who assist us in improving and optimizing our Site and Services, such as Google and Hotjar.
• Credit reference agencies for the purpose of assessing your credit score, where it is a contractual requirement.

Please note that the list above is not exhaustive, and in certain circumstances, we may need to share your personal data with other third parties. However, we will ensure that any such sharing is done in accordance with applicable laws and regulations.

Personal data we disclose to third parties

We may disclose your personal data to third parties in the following circumstances:

• In the event of a sale or purchase of any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or any member of our group of companies, or a substantial portion of their assets, is acquired by a third party, personal data held about our customers may be transferred as one of the assets.
• If we are legally obligated to disclose or share your personal data in order to comply with any legal obligation, enforce our terms and conditions, terms of use, or other legal agreements, or to protect our rights, property, safety, customers, or others. This may include sharing information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• We may share Aggregated Data, which does not personally identify individuals, in the normal course of our business operations. This may include sharing with other Site or Services users, our customers, or publicly to demonstrate trends or benchmark the general use of our Site and Services.

Please note that the above list is not exhaustive, and there may be other situations where we need to disclose your personal data in accordance with applicable laws and regulations.

International transfers

Our Services operate globally, and as a result, your personal data may be stored and processed in any country where we have operations, staff, or engage service providers. This includes countries outside your country of residence, where data protection laws may differ.

When processing your personal data, we will take all reasonable steps to ensure that it is treated securely and in accordance with this Privacy Policy. This includes ensuring that any transfers of personal data to countries outside the European Economic Area (EEA) or the UK comply with applicable data protection laws.

We will only transfer your personal data to countries that provide an adequate level of protection as determined by the European Commission or the UK Data Commissioner, or where appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, are in place.

Please be aware that our Site and Services are accessible worldwide via the internet. This means that if you choose to post your personal data on our Site or within the Services, it may be accessed from anywhere in the world. As a result, a transfer of your personal data outside the EEA or the UK may occur.

We strive to protect your personal data and maintain its security, regardless of the location of data processing or storage.

Data security

We have implemented appropriate security measures to safeguard your personal data and prevent unauthorized access, alteration, disclosure, or loss. For instance, all information you provide is stored on secure servers, and any credit card details or payment transactions are encrypted using SSL technology. If you have a password to access certain parts of the Site or Services, it is important to keep it confidential and not share it with others. We restrict access to your personal data to authorized personnel, including employees, agents, contractors, and trusted third parties who need to know the information for business purposes. They are bound by confidentiality obligations and will only process your personal data as instructed by us.

We have established procedures to handle any personal data breaches and, if legally required, we will promptly notify you and the relevant regulatory authorities.

While we strive to protect your personal data, it is important to note that transmitting information over the internet is not completely secure. Although we take reasonable precautions, we cannot guarantee the absolute security of data transmitted to our Site or Services. Any transmission is done at your own risk. Once we receive your personal data, we apply strict procedures and security features to prevent unauthorized access.

Link to other websites

Our Site and Services may occasionally include links to websites of our partner networks, advertisers, and affiliates. Please be aware that these websites have their own privacy policies, and we do not assume any responsibility or liability for their policies. Before submitting any personal data to these websites, we recommend reviewing their respective privacy policies.

Your rights

Under Data Protection Law, you have the right to request the following, free of charge:

• Access to your personal data.
• Rectification or deletion of your personal data.
• Restriction on the processing of your personal data.
• Objection to the processing of your personal data.
• Transfer of your personal data (data portability) in a structured, machine-readable, and commonly used format.
• Withdrawal of your consent to the processing of your personal data at any time.

To exercise any of these rights, please contact us as provided at the end of this Privacy Policy. We will respond to your queries within 30 days and handle your requests in accordance with Data Protection Law. If your request is complex or involves multiple requests, it may take longer to process. In such cases, we will notify you and keep you updated.

There is no fee to access your personal data or exercise your rights. However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply. To confirm your identity and ensure the security of your personal data, we may request specific information from you. We may also contact you for further details to expedite our response.

Marketing

Marketing: We may analyze your Identity, Contact, Technical, Usage, and Profile Data to determine your potential interests and needs. This helps us identify products, services, and offers that may be relevant to you (referred to as "marketing").

Promotional Offers from us: If you have opted in to receive marketing emails during registration on our Site or if you have inquired about or purchased our goods or services without opting out of receiving marketing communications, we will send you marketing emails.

Third Party Marketing: We will obtain your explicit consent before sharing your personal data with any third party for marketing purposes.

Opt out

If you change your mind about receiving marketing emails, you can opt out at any time by clicking the "unsubscribe" link at the bottom of any marketing email. Once you opt out, you will no longer receive marketing emails from us. However, we will continue to communicate with you via email regarding service billing and support. Additionally, we may send you push notifications occasionally to update you on service updates, events, and promotions. If you no longer wish to receive these communications, you can disable them in the settings on your device.

Data retention

We will retain your personal data for a duration that is reasonably necessary to fulfill the purposes for which it was provided or collected. This includes meeting legal, regulatory, tax, accounting, or reporting requirements. In certain circumstances, we may retain your personal data for a longer period, such as in the event of a complaint, when there is a prospect of litigation related to our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfill your request to unsubscribe from further messages.

In determining the appropriate retention period for personal data, we take into account factors such as the amount, nature, and sensitivity of the personal data, the potential risk of unauthorized use or disclosure of your personal data, the purposes for which we process the data, the availability of alternative means to achieve those purposes, and applicable legal, regulatory, tax, accounting, or other requirements.

We will retain your personal data for as long as we provide access to the Site or Services to you, as long as your account with us remains open, or as specified in any relevant contract you have with us. Typically, after you close your account or cease using the Services for a minimum of 60 days, we delete personal data.

After your account is closed, we may retain some anonymized information for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.

Please note: After closing your account or deleting information from your account, any information you have shared with others may remain visible. We do not have control over data that other users may have copied from the Site or Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

Complaints

If you have any concerns or complaints regarding our use of your personal data, please reach out to us using the contact information provided at the end of this Privacy Policy. Alternatively, you can contact your local data protection supervisory authority to address the issue.

Age of users

This Site and the Services are designed for individuals who are 16 years of age or older. It is not intended for and should not be used by anyone under the age of 16.

Changes to our privacy policy

If there are any changes to our Privacy Policy in the future, we will publish them on this page and, when necessary, inform you via email. We recommend checking this page regularly to stay updated on any modifications or revisions to our Privacy Policy.

This Privacy Policy was last updated on and supersedes any previously applicable Privacy Policy as of this date.

Contact

If you have any inquiries, comments, or requests regarding our privacy practices or this Privacy Policy, please contact us using the following methods:

By post: Strathmore 53 Bowleaze Coveaway, Preston, Weymouth, Dorset, DT3 6PL, United Kingdom

By email: privacy @ abtsolutions.net