FREEDOM INTERNET LIMITED (“Freedom Internet”, “we”, “us”, “our”), is committed to protecting the privacy and confidentiality of information it collects from its customers, website users, providers, contractors and other relevant third parties.

All Personal Data is collected in a fair and non-intrusive manner, with your consent. This Privacy Policy assists users of our website and purchasers / users of our goods or services (“you” or “your”) to understand:

• What Personal Data we collect and why we collect it;
• How we use Personal Data
• Who we share Personal Data with;
• The choices we offer, including how to access, update, and remove Personal Data.

Personal Data may include but is not limited to: identifying information such as name, physical address, age, payment details, telephone number and e-mail address.

By accessing and using our website or related services, you consent to the terms of this Privacy Policy and agree to be bound by them.

TYPES OF PERSONAL DATA WE COLLECT

We may collect your information in a number of ways, including:

• Directly from you, such as through information submitted to our website, information obtained during interaction with our website, correspondence, email, in person or by telephone.
• From third parties such as our related entities, business partners, credit reporting bodies or your representatives;
• From publicly available sources of information;
• From our existing records of how you use our products or services;
• When legally authorised or required to do so.

We have listed below the type of information (including Personal Data) we collect and our use of such information:

• Contact Information: information we collect to identify or contact you, such as your first and last name, physical address, email address, telephone number, as part of your use of our website and/or to provide you with our goods and services and the ongoing provision of such goods and services.
• Transaction Information: information related to your purchase of our goods and services and the ongoing provision of such goods and services.
• Billing Information: information we collect (including credit card and other payment information) in order to process any payments by you in relation to our goods and services and the ongoing provision of such good and services.
• Demographic Information: information we collect in relation to your age, sex and user preferences, for the purposes of our analytics and advertising purposes. Where you have consent to such use, we will provide demographic information to our partners and affiliates.
• Technical Information: We collect information in relation to your IP address, operating system and browser type, for system administration and analytical purposes; and information showing us from which app store you downloaded the Buddy by Freedom app.

Where the collection of Personal Data is necessary, you will be aware that such information is required because you will have to provide Personal Data when utilising our website or using / purchasing our goods or services. The supply of your information (including Personal Data) is voluntary, however, if you do not supply certain Personal Data, you may not be able to use certain parts of our website and / or use or purchase our goods or services.

HOW WE USE YOUR INFORMATION

We use information (including Personal Data) held about you for the primary purpose for which you have provided the information (and information about others that you have provided us with). In addition, we also use and disclose information for purposes ancillary and consequential to the primary purpose of collection, such as:

1. to provide, administer, and improve our goods and services;
2. to maintain and improve the functionality or performance of our goods, services and website;
3. to process financial transactions related to our services;
4. to send notices, including technical, administrative or legal notices;
5. to better understand your needs and interests;
6. to fulfil requests you make with Freedom Internet;
7. to personalise your experience when using or purchasing our goods or services;
8. to provide Freedom Internet service announcements;
9. if you have provided your express consent, to provide you with information and offers from Freedom Internet, Freedom Internet Affiliates, our business partners and other third parties (as applicable);
10. to protect, investigate, and deter against fraudulent, harmful, unauthorised, or illegal activity; and
11. to comply with legal obligations.

If you have provided us with your consent to receiving promotional / marketing or other communication from Freedom Internet, Freedom Internet Affiliates, our business partners and other third parties (as applicable) you have the right to withdraw (i.e. ‘opt-out’) from receiving promotional /marketing communication from Freedom Internet at any time by contacting Freedom Internet on the contact details provided in this Privacy Policy. For the avoidance of doubt, should you wish to opt-out from receiving promotional / marketing communication from Freedom Internet’s partners / affiliates and third parties, you will need to unsubscribe directly with the relevant third parties, using their processes.

JUSTIFICATION OF USE

We will only use your Personal Data if we have a lawful basis and legal grounds for doing so. These are the principal grounds that justify our use of your information:

• Consent: where you have expressly consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
• Contract performance: where your information is necessary to enter into or perform our obligations to you;
• Legal obligation: where we need to use your information to comply with our legal obligations;
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
• Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.

If you are using our website, purchasing or using our goods and/or services on behalf of a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us. For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

WHERE WE STORE YOUR PERSONAL INFORMATION

The information you provide to us is stored on computer and paper-based files as appropriate. The secure storage and use of information is important to us and we endeavour to take reasonable steps to protect the information from misuse or loss, or unauthorized access, modification or disclosure.

However, no data is entirely secure and safe from a breach or failure of data backup and security. Accordingly, whilst we take reasonable steps in relation to security of its services, we exclude all warranties and disclaim to the full extent permitted by law all liability in relation to data backup and security.

All staff with access to your personal information are bound by duties of confidentiality. The disclosures of information listed above may involve transmitting, storing or processing information across national borders. This includes (amongst other things): our right to host the website on servers located in countries other than Australia or New Zealand; our right to conduct usage analysis; and our right to process payments. You consent to the transmission of data for these purposes.

Where we collect Personal Data from users based in the European Economic Area (“EEA”), such data is processed and stored on Amazon Web Services (Ireland) Cloud Servers. If this applies to you, you acknowledge that this data may however be processed by staff operating outside of the EEA who work for us.

HOW LONG WE STORE YOUR CUSTOMER ACCOUNT DATA

Freedom Internet will store the information it collects from you as long as needed to provide you with our goods and services (including the ongoing provision of such goods and services (if any)), to fulfil the purpose(s) for which it was collect and to operate our business

Invoice records, including their digital equivalent, may be retained in identifying form by Freedom Internet for longer periods for accounting, tax, and audit purposes depending on and in accordance with applicable tax law.

DISCLOSURE OF YOUR INFORMATION

You acknowledge that we may share Personal Data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to our website and our goods and services. These parties include:

• Third parties who act for us or provide services for us, such as billing and credit card payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting, security and database management services;
• Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance, and corporate governance;
• Any third party for the purposes of aggregating user statistics and other information that does not personally identify you, to third parties such as our advertisers, customers and partners.
• Freedom Internet Affiliates, including persons or entities that acquire some or all of Freedom Internet or our assets;
• Anyone we transfer our business to in respect of which you are a customer or a potential customer;
• Law enforcement, national security agencies, and other government and regulatory authorised as required or authorised by law.

Where you have provided your consent to us doing so (and not opted out of receiving such material), Freedom Internet may disclose your Personal Data, such as phone numbers, mailing address, personal preferences and demographic details (such as age and gender) to its carefully selected third parties, such as its service providers and business partners. You acknowledge that such third parties may use your Personal Data (where you have consented to such use) to contact you for advertising, marketing and promotional purposes.

SECURITY

We use commercially reasonable security measures to protect against the loss, misuse, and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit, and enforcement of least privilege and need-to-know principles.

To the extent the Service requires you to provide any Financial Account Information, such as when you purchase or goods or subscribe to our services, that information will be collected and processed by third-party PCI-compliant service providers.

THIRD-PARTY SITES

This Privacy Policy applies to the collection of Personal Data by Freedom Internet associated with the provision of providing our website to you and facilitating your use of Freedom Internet’s services and purchase of Freedom Internet’s goods.

Our website may contain links to third party web sites for your convenience and information. We do not control those sites or their privacy practices. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or web site before submitting your Personal Information. Some third parties may choose to share their personal data with us; that sharing is governed by that third party’s privacy policy.

WHAT RIGHTS AND CHOICES DO YOU HAVE REGARDING YOUR PERSONAL DATA?

Freedom Internet will take all reasonable steps to ensure that your information (including Personal data) is accurate, up-to-date, complete, relevant and not misleading.

You have the right to access, request a correction and to delete your Personal Data held by Freedom Internet. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests as soon as possible. The following includes rights you have in relation to your Personal Data:

• Right to rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Right to erasure / ‘Right to be forgotten’: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide a good or service to you, you may not be able to receive that good or service.
• Right to data portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Right to restriction of processing / Withdrawal of consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our service. You can ask us to restrict further processing of your Personal Data. You also have the right to lodge a complaint about Freedom Internet practices with respect to your Personal Data.
• Right to complain: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.
• Closing Your Account: You may close your account (if any) with Freedom Internet and upon such termination, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, Freedom Internet may nevertheless retain your Personal Data to protect the business interests of Freedom Internet and Freedom Internet Affiliates, vendors, and other users, and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.

For all requests and enquiries relating to your rights set out above, please email us at administrator@freedominternet.co.nz

Freedom Internet will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the relevant Personal Data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

ENFORCEMENT AND RECOURSE

We take our privacy commitments very seriously. We will conduct internal audits of our compliance with this Privacy Policy, and work to ensure that our employees and service providers also adhere to the Privacy Policy. If you have any questions or concerns regarding privacy related to the Buddy and/or our related services, please send us a detailed message to administrator@freedominternet.co.nz, and we will try to resolve your concerns.

COOKIES

On occasion, we may gather information about your computer for our services and to provide statistical information regarding the use of our website to our advertisers. Such information will not identify you personally; it is statistical data about our visitors and their use of our site. This statistical data does not identify personal details.

Similarly to the above, we may gather information about your general internet use by using a cookie file. Where used, cookies are downloaded to your computer automatically. The cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and the service that we provide to you. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline cookies. If you use our site without changing your browser settings, we will assume that you are happy to receive all cookies on the website.

Please note that should you choose to decline cookies, you may be unable to access particular parts of our website. Our advertisers or partners may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on their links on our website.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit wikipedia.org, www.allaboutcookies.org, or www.aboutcookies.org.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via email (if you have an account where we have your contact information) or otherwise by posting an update of the Privacy Policy on our website. Any change Freedom Internet makes applies from the date we post it on our website (or otherwise notify you). By continuing to use our website and/or purchasing / using our goods or services, after the publication of any amended Privacy Policy, you are agreeing to be bound by the new / amended Privacy Policy.

WHAT IF YOU HAVE QUESTIONS REGARDING YOUR PERSONAL DATA?

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at administrator@freedominternet.co.nz