Freede Offerings

Last modified: May 17, 2024

Freede Solutions Inc. (“Freede”, “we”, “us” or “our”) respects your privacy. In this privacy policy (“Offerings Privacy Policy”), we describe how we collect, use, share, disclose, and protect your Personal Information when you use our software as a service products (together the “Offerings”), including any content, features, functionality, applications, and services offered on or through the Offerings.

We may modify this Offerings Privacy Policy at any time at our discretion. Material changes will be conspicuously posted on the Offerings or otherwise communicated to you. All changes will be effective immediately upon posting to the Offerings.

WHAT IS PERSONAL INFORMATION?

“Personal Information” means information that alone or in combination 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 WE COLLECT

We collect the following categories of Personal Information.

Identifiers such as your name, email address, mailing address, postal code, phone number, IP address, unique personal identifiers, and device name.

End User Records such as a record of products or services you have received.
Agency Partner Information such as the collectors, processors, or owners of one or more of your debt accounts that have selected you for registration on the Offerings (“Agency Partner”).

Transaction Information such as details of the transactions you carry out through our Offerings, including the making of payments to the applicable Agency Partner on your debt account through a third party payment provider.
Debt Account Information - current detailed information about your consumer debt accounts placed with the applicable Agency Partner for processing or collection, or that the Agency Partner owns. Your Agency Partner(s) will only share with us the information you have given them consent and authorization to provide to us.
Payment Information - You may be required to provide financial information to submit a payment to an Agency Partner through the Offerings. We rely on a third party payment provider to process this information and do not store any credit card or bank account numbers.

HOW WE COLLECT PERSONAL INFORMATION

Information You Provide to Us

We collect Personal Information directly from you. For example, we may collect Personal Information when you

Create an account on the Offerings,
Utilize our Offerings,
Complete questionnaires, request further services or products or report a problem with our Offerings,

Respond to surveys that we might ask you to complete for research purposes, and

Make payments on your debt accounts through the Offerings.

Information We Collect Automatically Through Technology

We collect information about your computer or other electronic device when you visit our Offerings. This information may include your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, browser type, operating system, location, pages you click, date and time of your requests, and the amount of time spent on the Offerings.

We may associate this information with Personal Information we collect from other sources, or that you provide to us or that we receive from third parties. This helps us improve our Offerings and deliver a better and more personalized service, by enabling us to estimate our audience size and usage patterns and analyze how the Offerings are used.

Information from Third Parties.

Agency Partners: With your consent and authorization, your Agency Partner(s) may provide us, or give us access to through an application programming interface, current detailed information about your consumer debt accounts placed with them for processing or collection, or owned by them.
Payment Providers: From your financial institutions, social media, and other similar sources that you authorize us to access. For example, we allow you to connect your bank account information through Plaid. For more information regarding using Plaid, please visit its Terms of Use at https://www.freede.co/legal-terms-platform/.
Connected Accounts: To the extent you have given Freede authorization, Freede may from time-to-time access and obtain information from your accounts at financial institutions and your accounts on social media platforms, such as Twitter and Reddit.
Others: From third parties, including our business partners and third-party service providers.

HOW WE USE YOUR PERSONAL INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information, for a variety of business reasons, including:

To present you with our Offerings and content.
To identify you when you visit the Offerings.
To provide you with notices about your account registration, account status, preferences, and other matters related to your use of the Offerings, including customer service messages.
To determine what individualized information to present to you and give you access to.
To provide you with information about your debt accounts with your Agency Partners.
To provide you with general and personalized information designed to inform you about your financial condition.
To provide you with tools, including the AI Tools.

To provide you with notices about your debt accounts with your Agency Partner.
To provide you with notices about the status and changes in various aspects of your financial condition.
To allow you to communicate with your Agency Partner using communication tools available to you on the Offerings, including the Freede Chat.
To allow your Agency Partner to send you notices and otherwise communicate with you using the tools available to them on the Offerings.

To contact and gather information about you from third parties (such as your financial institutions and social media platforms) with respect to which you have given us authorization and permission.
To provide you with information, products, or services that you request from us.
To respond to your emails or online requests or comments.
To notify you about changes to our Offerings or any products or services that are offered through our Offerings.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To deliver and process surveys and personalize and improve the usability of the Offerings.
To fulfill any other purpose for which you provide it.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

‌DISCLOSURE OF YOUR INFORMATION

We may disclose anonymized and/or aggregated information about our users, and information that does not identify any individual, without restriction. This information is not considered Personal Information.

We may disclose your Personal Information that we collect or you provide as described in this Offerings Privacy Policy in a variety of ways including, but not limited to:

To your Agency Partner.
To our subsidiaries and affiliates.

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

To a potential buyer, buyer or other successor in the event of due diligence, a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Freede’s assets or equity, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your Personal Information held by Freede is among the assets transferred.

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our Terms of Use at https://www.freede.co/legal-terms-Offerings/ and other agreements, including our agreements with your Agency Partners.

For any other purpose we disclosed when you provide the information or with your consent.

ACCESSING, CORRECTING, AND DELETING YOUR PERSONAL INFORMATION

You can review and change your Personal Information by logging into the Offerings and visiting your account profile page.

You may also send us an email at contact@freede.co to request access to the Personal Information that you have provided to us or to correct, revise, or delete that information. We will not accommodate any request that we reasonably believe violates any law or legal requirement or would cause the information to be incorrect.

For any requests related to the Personal Information that your Agency Partner provided to us, please contact you Agency Partner.

Deleting Your Account

You can “de-register” your account once you have terminated your connection to all Agency Partners. Once you do so, you will not be able to access your account. If your Agency Partner, or all Agency Partners if you use the Offerings in conjunction with more than one Agency partner, de-registers your account, you will no longer be able to access the Offerings and we will delete your Personal Information as described below.

When we delete your Personal Information, we will delete it from our active databases or anonymized it so that the data is no longer identified with you, but the data may remain in our archives if Freede determines that it is not practical or possible to delete it.

We will not delete Personal Information you provide to your Agency Partner through the Offerings or their features. To delete or change this information, you must contact your Agency Partner(s).

CHILDREN

Our Offerings are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at contact@freede.co.

SHINE THE LIGHT

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Offerings that are California residents who provide Personal Information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the Personal Information we shared, if any, with other businesses for their own marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such Personal Information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To make such a request, please send an email to contact@freede.co.

AI TOOLS

When you use our Offerings, you may have access to our artificial intelligence powered tools (“AI Tools”) including Freede Chat and the AI Coach.

“Freede Chat” is an automated online “agent” that is modified by your Agency Partner and provides helpful information about how to use the Offerings and enables you to communicate with your Agency Partner(s) about your debt account.

The “AI Coach” is a wellness tool that uses artificial intelligence to interact with you. Unlike the Freede Chat, the AI Coach is separate from your relationship with your Agency Partner, and we do not share your interactions with the AI Coach with your Agency Partner. The AI Coach is not a person. Rather, it is a chat function powered by generative AI technology.

Your use of these tools is voluntary. They are not intended to provide financial advice.

DATA SECURITY

We have implemented commercially reasonable security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

LINKING TO OTHER INTERNET SITES

You should be aware that other Internet sites that are linked from the Offerings or from a Freede email message may contain privacy provisions that differ from the provisions of this Offerings Privacy Policy. We do not have control over, or responsibility for, the content or operation of any websites other than the Offerings. These other sites may send their own cookies to your device, may independently collect data or solicit personal information, and may or may not have their own published privacy policies. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Depending on which Offerings you use, we may use cookies, pixels, and other web tracking technologies (collectively, “Cookies”) to collect Personal Information and analytics data when you use certain Offerings.

What Are Cookies? Cookies are small text files that are stored on your device. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/.

We use Cookies to help operate our website and Offerings and to obtain analytical information about how you use our Offerings.

Types of Cookies

Essential Cookies. These Cookies are required for a website to function properly and are necessary to enable basic features.

Functional Cookies. These Cookies help enhance a website’s performance and functionality, by, among other things, remembering user credentials for automatic login or a user’s preferences.

Analytics Cookies. We use Analytics Cookies to collect information about how you use our Offerings such as which pages you visit regularly. We use this information to identify how users engage in various features we deploy as well as to assist in the analysis, testing, observation, and deployment of new features.

How You Can Opt-Out of Cookies

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including Essential Cookies) you may not be able to access all or parts of the Offerings.

BREACH NOTIFICATION

In the event we determine the occurrence of a data security incident, we will notify you as required by law.

CONTACT INFORMATION

If you have questions or concerns about this Offerings Privacy Policy or our privacy practices, please contact us at contact@freede.co.