The Privacy Policy is effective 1st January 2023.

If you live in the European Union (“EU”) or United Kingdom (“UK”), this section applies to you.

These privacy notices are provided as a supplement to our Privacy Policy. For a more complete understanding of our privacy practices and how we handle personal information, please read our Privacy Policy.

1. Controllers.

European Union, United Kingdom. Freedom Machine is the controller for personal data relating to data subjects located in the EU and UK. 

Email: privacy@freedommachine.app
You may reach our Data Protection Officer at dpo@freedommachine.app

2. On What Legal Bases Do You Collect My Information?

To the extent required by applicable law, we will collect your personal data with your consent where required and in accordance with our legitimate need to provide you our Services.

Under European data protection laws, Freedom Machine is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

2.1 Performing the Member Agreement.
Freedom Machine processes your information as is necessary to perform our contract with you, the Member Agreement. For example:

• We use your information in order to create your account and set you up as a Member on Freedom Machine.

• We transfer your information outside of the EU to the United States, in order to provide our Services.

2.2 Your Consent.
Freedom Machine processes certain information based on your consent, which you may revoke at any time. For example:

• We and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent.

• If you decide to use location services in the context of Freedom Machine, we collect and process such location information based on your consent.

• We will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.

• When you ask us to notify you when Freedom Machine is available in your geographic region, we do so based on your consent.

2.3 Legal Obligation.
Freedom Machine may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:

• We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement).

• We may retain and process your information where it is necessary for compliance with applicable tax laws.

2.4 Vital Interests.
Freedom Machine might process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:

• We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person, including you, other Members, Visitors, our staff, or the public.

• We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.

2.5  Legitimate Interests.
We may process your information where it is necessary for the purposes of Freedom Machine’s or a third party’s legitimate interests, such as those of Visitors, Members or partners. In particular, we process your information in furtherance of the following legitimate interests:

• Keeping our Services safe and secure. We use your information because it is necessary to pursue our and our Members’ legitimate interests in ensuring Freedom Machine is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Member Agreement.

• Providing, improving, and developing our Services. We use your information to provide our Services, including any personalised services, and to understand and improve our business and our Member relationships. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Members on a sustained basis.

• Sending marketing communications. We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.

• Sharing information for legal and safety reasons. Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.

As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

3. What Are My Rights?

You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.

In certain cases, such as for access to, rectification or deletion of your information, please be sure to read the options you have under the “What are My Choices” section above.

3.1. Access and portability.
If you are unable to obtain the desired information by logging into your Freedom Machine account, or if you are not currently a Freedom Machine Member, email us at privacy@freedommachine.app to request a copy of your Freedom Machine information. If requested and required to do so by applicable law, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties as you request.

3.2 Rectify, restrict, delete.
You can access, rectify, and delete your Freedom Machine information by logging into your Freedom Machine account. If you cannot do this or you do not have a Freedom Machine account, please contact us and we will rectify, restrict, or delete your information if requested and if required to do so by applicable law.

3.3 Object to certain processing.
If we process your information based on our legitimate interests explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing (including if we are permitted to continue processing under applicable law) or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by using the unsubscribe link in such communications, changing your email account settings or, if you do not have an account, by contacting us.

3.4 Revoke consent.
Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time. If you withdraw your consent to the use of your information for the purposes set out in this Privacy Policy, you may not have access to all (or any) of our Services and we may not be able to provide you all (or any) of our Services under this Privacy Policy and our Member Agreement. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities. Please also understand that, if you withdraw your consent, that does not impact the lawfulness of processing that occurred before your consent was withdrawn.

3.5 Lodge a complaint.
If you have a EU Member account and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority. Similarly, if you have a UK Member account, you have the right to lodge a complaint with the UK Information Commissioner’s Office.

We take all privacy complaints seriously and will assess any complaint with the aim of resolving it in a timely and efficient manner.

4. Where Is My Information Stored and Transferred?

If you live in Europe, we may transfer your personal data to other jurisdictions where we have facilities or service providers, such as the United Kingdom or United States, where data protection laws may not provide the same protections as the laws of your home country.

For residents of Europe, the United States is not subject to an adequacy decision, i.e., the European Commission has not determined, under Article 45 of Regulation (EU) 2016/679 (GDPR), that the United States ensures an adequate level of protection for personal data under its laws. (An explanation of adequacy decisions and list of recognised jurisdictions can be found here.)

When we transfer personal data of data subjects in Europe to a third country that is not subject to an adequacy decision, we will do so in accordance with all applicable data protection laws. We may rely on standard contractual clauses to provide an adequate level of protection for personal data. “Standard contractual clauses” refers to contracts between companies transferring personal data from Europe to third countries, such as the United Kingdom and United States that contain standard commitments approved by the European Commission protecting the privacy and security of the personal data  transferred.


5. How Can I Contact Freedom Machine?

Contact us at:
Email: privacy@freedommachine.app
You may reach our Data Protection Officer at dpo@freedommachine.app