PRIVACY POLICY
Effective date: May 22, 2023
Last updated: May 3, 2024
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www.thefreemeapp.com (the “Site”) and the FreeMe app (the “App”) is owned and operated by FreeMe LLC. FreeMe LLC can be contacted at:
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support@thefreemeapp.com
(702) 246-2827
401 Ryland St., Ste 200-A, Reno, NV 89502
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Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:
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The personal data we will collect;
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Use of collected data;
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Who has access to the data collected;
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The rights of Site users; and
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The Site’s cookie policy.
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This Privacy Policy applies in addition to the terms and conditions of our Site.
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GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
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Consent
By using our Site users agree that they consent to:
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The conditions set out in this Privacy Policy.
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When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
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You can withdraw your consent by e-mailing us at support@thefreemeapp.com
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Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
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We rely on the following legal bases to collect and process the personal data of users in the EU:
Users have provided their consent to the processing of their data for one or more specific purposes; and
Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are: Providing user summaries of information given and calculations for timecards and invoices.
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Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.
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Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:
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IP address;
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Location;
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Hardware and software details;
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Clicked links; and
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Content viewed.
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Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
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First and last name;
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Age;
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Date of birth;
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Sex;
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Email address;
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Phone number;
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Address;
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Social Security Number;
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Financial Information (such as credit card numbers, household income, etc);
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Education;
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Work Experience; and
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Company Loan Out Information
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This data may be collected using the following methods:
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Form submission
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Creating an account; or
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Using our FreeMe app and inputting information
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How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
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The data we collect automatically is used for the following purposes:
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Marketing; and
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Analytics
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The data we collect when the user performs certain functions may be used for the following purposes:
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Sending newsletters and updates about FreeMe;
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Display in personal profile account;
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Populating into timecard or invoice templates; and
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Providing better services for our consumers
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Who We Share Personal Data With
Employees
We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
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Third Parties
We may share user data with the following third parties:
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Google analytics
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Development company in India (Codonnier)
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We may share the following user data with third parties:
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Links clicked while using the website; and
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User information
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We may share user data with third parties for the following purposes:
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Targeted advertising
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Fixing bugs and maintenance
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Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.
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Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:
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If the law requires it;
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If it is required for any legal proceeding;
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To prove or protect our legal rights; and
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To buyers or potential buyers of this company in the event that we seek to sell the company.
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If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
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How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.
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You will be notified if your data is kept for longer than this period.
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How We Protect Your Personal Data
In order to protect your security, we use browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
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While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
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International Data Transfers
We transfer user personal data to the following countries:
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India
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When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.
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If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
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The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
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We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient.
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Your Rights as a User
Under the GDPR, you have the following rights:
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Right to be informed;
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Right of access;
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Right to rectification;
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Right to erasure;
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Right to restrict processing;
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Right to data portability; and
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Right to object.
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Children
The minimum age to use our website is 18 years of age. We do not knowingly collect or use personal data from children under 13 years of age. If we learn that we have collected personal data from a child under 13 years of age, the personal data will be deleted as soon as possible. If a child under 13 years of age has provided us with personal data their parent or guardian may contact our privacy officer.
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How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, or if you would like your data to be deleted or modified in any way, please contact our privacy officer here:
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Erica Chan
support@thefreemeapp.com
(702) 246-2827
401 Ryland St., STE 200-A, Reno, NV 89502
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You may also request to delete your account by filing out our form online.
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Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third party websites and therefore do not respond to browser-initiated DNT signals.
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How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
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You can opt-out of the use of your personal data for marketing emails. You can opt-out by clicking “unsubscribe” or e-mailing us at support@thefreemeapp.com.
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Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Site:
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Functional cookies: Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
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Analytical cookies: Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc; and
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Targeting cookies: Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalize the information you see on our Site for you.
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Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.
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Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority.
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Contact Information
If you have any questions, concerns or complaints, you can contact our privacy officer, Erica Chan, at:
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support@thefreemeapp.com
(702) 246-2827
401 Ryland St., STE 200-A, Reno, NV 89502
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CALIFORNIA CONSUMER PRIVACY ACT PRIVACY NOTICE
Website: www.thefreemeapp.com
This Privacy Notice supplements the www.thefreemeapp.com Privacy Policy and applies solely to California consumers who visit www.thefreemeapp.com. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this Privacy Notice.
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Information We Collect
We have collected the following categories of personal information about consumers in the past twelve (12) months:
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Identifiers such as a real name, alias, postal address, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
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Categories of personal information described in California customer records law (Cal. Civ. Code § 1798.80(e)) such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
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Characteristics of protected classifications under California or federal law, such as sex, race, age, disability, national origin, or religion;
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Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
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Internet or other electronic network activity information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
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Professional or employment-related information such as occupation, job history, or employer information; and
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Inferences drawn from any of the personal information listed above to create a profile about a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
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Sources of Information
We collect the categories of personal information listed above from the following categories of sources:
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Directly from user submission; and
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Indirectly from user activity on our website.
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Use of Personal Information
We may use or disclose personal information for one or more of the following business purposes:
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send you promotional emails; and
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provide services you requested from us.
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Sharing Personal Information
We have not disclosed consumer personal information in the past twelve (12) months.
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Sale of Personal Information
We have not sold consumer personal information in the past twelve (12) months.
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Your Rights and Choices
The CPPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise those rights.
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Access to Specific Information and Data Portability Rights
You have the right to request that www.thefreemeapp.com disclose to you certain information about our collection and use of your personal information in the past 12 months. Once we receive and confirm your verifiable consumer request (see the Exercising Your Access and Deletion Rights section below), we will disclose to you:
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The categories of personal information we collected about you;
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The categories of sources from which we collected personal information about you;
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Our business or commercial purpose for collecting or selling personal information;
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The categories of third parties with whom we share personal information; and
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The specific pieces of personal information we have collected about you (also called a data portability request).
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Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Once we have received and confirmed your verifiable consumer request, we will delete, and direct any of our service providers to delete, your personal information from our records, unless an exception applies.
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We may deny your deletion request if retaining the information is necessary for us or our service providers to:
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Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
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Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
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Debug products to identify and repair errors that impair existing intended functionality;
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Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
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Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
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Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
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Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
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Comply with a legal obligation; or
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Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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Exercising Your Access and Deletion Rights
To exercise your access and deletion rights described above, please submit a verifiable consumer request to us by:​
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Emailing us at support@thefreemeapp.com; or
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Requesting to delete your account via our online form
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You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
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Provide enough information for us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
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Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You are not required to make an account with us to make a verifiable consumer request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
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Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically or by mail, at your option.
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Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
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Non-Discrimination
You have the right to not be discriminated against in pricing and services because you exercise any of your CCPA rights. Unless permitted by the CCPA, we will not use whether or not you have exercised your CCPA rights to:
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Deny you goods or services;
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Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
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Provide you a different level or quality of goods or services; or
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Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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Changes To This Privacy Notice
We may amend this Privacy Notice from time to time to maintain compliance with the law and to reflect any changes to our data collection process. We recommend you check this Privacy Notice from time to time to ensure you are aware of any changes. If necessary, we may notify you by email of changes to this Privacy Notice.
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Contact Information
If you have any questions or concerns, you can contact us at:
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Erica Chan
(702) 246-282
support@thefreemeapp.com
401 Ryland St., Ste 200-A, Reno, NV 89502
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