Other Covered Entities

Freedcamp, Inc

Industries

  • Information and Communications Technology
  • Software
  • Application Software

Participation

EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 6/3/2018
Next Certification Due Date: 6/3/2019
Data Collected: NON-HR

Swiss-U.S. Privacy Shield Framework: Active

Original Certification Date: 6/3/2018
Next Certification Due Date: 6/3/2019
Data Collected: NON-HR

Purpose of Data Collection

We collect data such as: email address, customer names, company names, IP address, service metadata, device information, project information. Freedcamp is a work collaboration platform, therefore Users use us to work on projects with their team. Any project data provided by Users will be stored by Freedcamp so Users can easily access it anytime. We do not store financial data(credit cards, etc), but utilize Stripe as a our payment processor.

Privacy Policy

Non-HR Data

Description:

Freedcamp Privacy Policy Effective 5/18/2018 This Privacy Policy describes the manner in which Freedcamp collects, uses, maintains and discloses information collected from Users ("User") through our all our websites ("Site") by accessing our Services (“Services”). This privacy policy applies to the Site and all products and services offered by Freedcamp, INC. If you do not agree with this policy, please do not access or use our Services or any aspect of our Business. Updates in this Privacy Policy reflects recent changes in data protection law (eg. GDPR) and aims to provide Users a clearer understanding of how Freedcamp manages all User Data. Table of Contents Applicability Data Collected and Received by Freedcamp How Freedcamp Use Collected Data Sharing and Disclosure of Information Data Deletion Data Retention Security Age Limitation Changes to Privacy Policy Privacy Shield Data Protection Officer User Rights Contact Information Applicability This privacy policy applies to all products and Services (collectively, the “Services”) offered by Freedcamp, INC through Freedcamp.com and other Freedcamp websites (collectively, the “Sites”) and our Mobile Application. In addition, this policy applies to personal data from the European Union that is collected and retained in the United States. This Privacy Policy does not apply to any third party applications or software that integrate with Freedcamp’s Services or any other third party products, services or business. Data Collected and Received by Freedcamp Personal Identification Information We may collect personally identification information from Users in a variety of ways, including, but not limited to, when Users visit our Sites, register on the Sites, and in connection with other activities, Services, features or resources we make available on our Sites. Users may be asked for, as appropriate, name, email address, billing information. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Sites related activities. We will never sell your personal information to third parties and we won’t use your name or company name in any marketing statements without obtaining your permission in writing. Non Personal Identification Information We may collect non-personal identification information about Users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Sites, such as the operating system and the Internet service providers utilized and other similar information. Other Information Services Metadata – when Users interact with our Services, metadata is generated to help provide additional context regarding how Users interact with our Sites. Log Data – Our services will automatically collect information when Users access or use our Sites or Services and records it in log files. Log data may include IP address, previously visited web page addresses, browser type and settings, time and date when Services were used, browser configurations and plugins, language and cookie data. Device Information – Freedcamp collect information about your computer, phone, tablet, or other devices you use to access our Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services. Location information - Freedcamp will receive this information from Users during our Account Registration as well as from our vendor partners to approximate your location. Project information – Freedcamp is a work collaboration tool, therefore any User generated data by use of our Services will be collected and stored by Freedcamp, and vendor partners. Collected data includes, but not limited to, data that Users post, send, receive, or share. These includes any files or links that User upload to our Services. Project data will only be accessible through authorized accounts or Users designated account and can only be viewed, or altered, by Users assigned to such projects. Freedcamp will never share, sell, or exploit ay Project information unless requested by Project Admins. In addition, we may also inadvertently receive information about such Users from same project members. For example, a specific User may be mentioned by one of their project members when using our Services. Web Browser Cookies Our Site, and/or vendors, may use "cookies" to enhance User experience. User`s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. How Freedcamp Use Collected Data Users are the primary Controllers of User Data. Freedcamp is a processer of User Data and Controller of other certain data. Users who resume the role of Project Admins will have the rights to grant or remove access to Project Data to any other Users. Freedcamp will never remove Users from any Projects unless specifically instructed by Project Admins or Users failed to provide payment for Freedcamp’s services (see Terms of Service for additional information). Freedcamp collects and uses Users personal information for the following purposes: 1. To personalize User experience 2. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site. 3. To improve our Site 4. We continually strive to improve our website offerings based on the information and feedback we receive from you. 5. To improve customer service 6. Your information helps us to more effectively respond to your customer service requests and support needs. 7. To administer a content, promotion, survey or other Site feature 8. To send Users information they agreed to receive about topics we think will be of interest to them. 9. The email address Users provide will only be used to respond to their inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email. 10. As required by applicable law, legal process or regulation 11. For Billing, account management and other administrative matters 12. For investigative and preventive measures against Site abuse 13. We use information about Users when granted consent for a specific purpose not listed above. For example, we may publish testimonials or feature customer stories to promote our Services. We will always ask for consent prior to posting any information for promotional purposes. Sharing and Disclosure of Information Freedcamp will only disclose or share User information for the following purposes: 1) User’s Request: Freedcamp will share all User Data based on User’s request and instructions. 2) Project Collaboration: Users can create content, which may contain information about themselves or other Users, and grant permission to others to see, share, edit, copy and download that content. Some of the collaboration features of the Services display some or all of your profile information to other Service Users when you share or interact with specific content. Similarly, when Users join a project, your name, profile picture and contact information and will be displayed in a list for other project members so they can find and interact with you. 3) Third Party Service Providers and Partners: Freedcamp works with third-party service providers and partners to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for Freedcamp, which may require them to access or use User information. If a service provider needs to access information about Users to perform services on Freedcamp’s behalf, they do so under instruction from Freedcmap, including abiding by policies and procedures designed to protect User information. To Freedcamp’s knowledge, our 3rd party Service Providers and Partners are in compliance with GDPR. Please email us for additional information. 4) Legal Compliance: If requested by legal Authority, Freedcamp may disclose User information that we determine to be in accordance or required by any applicable law. 5) Enforcement: Freedcamp also reserve the right to disclose User information to investigate, prevent, or take action against illegal activities, suspected fraud, or situations involving physical threat to any such persons. 6) Consent: Freedcamp may share User information with other 3rd parties in instances when we have Users’ consent to do so. The operations of Freedcamp does require our employees to have access to systems which store and process User Data. This primarily serves the purpose of problem diagnostic or troubleshooting. For example, in order to diagnose a problem Users may have with Freedcamp services, our Employees may need access to your User Data. All employees are prohibited from viewing User Data for any reasons unless absolutely necessary to do so. Data Deletion When Users delete their account(s) or fail to make payment for any business plans, there are different scenarios how data deletion will be treated as described below: A. If you were not invited to any other projects owned by other Freedcamp User then your data can no longer be accessed by you or any other Users that you invited to Freedcamp. Complete data deletion will occur post 90 days. Please see “Data Retention” below for additional details regarding 90 day data retention. B. If User does not own projects and was only invited to other Freedcamp User’s projects then your specific contribution in other the projects will remain, but your personal information will be deleted. Freedcamp will make every effort to mask any personal information remaining, for example, your contribution to someone else’s project will be listed as “John Doe” with no connection to your deleted personal information. C. If you own projects and were participating in other Users’ projects, then Freedcamp’s Data Deletion and Data Retention will apply to each category described in section A and B above. Users, at any time, may request a deletion of their personal data. If such request is made, the following scenarios as mentioned above will still apply. Data Retention Information storage and security Freedcamp use data hosting service providers in the United States to host collected information, and we use technical measures to secure all data. Despite the thorough security measures and safeguards that Freedcamp implements to protect data, no security system is impenetrable and due to the inherent nature of the Internet, Freedcamp cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. Freedcamp has policies in place in case of such situation and will respond to requests about this within a reasonable timeframe. How long we keep information How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will make every effort to delete your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. • User Account information: We retain User information until User delete their account(s), which then we will continue retaining the data for up to 90 days after account deletion. Freedcamp maintains this practice due to the following reason: o In the event that User’s account has been compromised and purposely deleted. Freedcamp will help maintain and restore data once the situation is rectify o Account was mistakenly deleted by Users. In such an event, Freedcamp will be able to restore data for Users. o Various data storage systems and backups have different lifecycle policies which is held for a maximum of 90 days. For example, our database backups are encrypted, incremental and full re-cycle in 30 days. It is impossible to erase User data inside up to 1 minut eprecision encrypted incremental backups. o If User initially canceled their account and requested but later change their mind. User will be able to have all data restored if account is reactivated within 90 days after initial account cancellation. o Freedcamp may also retain some of User data as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies any specific Users, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about any Users. • Information you share on the Services: If User’s account is deactivated or disabled, some of User information and the content that Users have provided will remain in order to allow other Project members or other Users to make full use of the Services. For example, we continue to display comments and content you provided to boards or cards. Freedcamp will hold User data up to 90 days after account cancellation in case Users will renew again within that time frame. • Marketing and Promotional information: If Users have elected and provided consent to receive marketing and promotional emails from Freedcamp, we retain information about Users’s marketing preferences unless asked specifically to delete such information. Freedcamp retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. Security We take the security of your data very seriously at Freedcamp. As transparency is one of the principles on which our company is built, we aim to be as clear and open as we can about the way we handle security. A summary of our security practices can be viewed on our site. Age Limitation Freedcamp does not allow the use of our Services or Sites to anyone younger than 16 years old unless Consent is provided in writing by a legal guardian. Freedcamp will make the utmost effort to prohibit use of our Site by anyone not over the legal age. Should Freedcamp learn that anyone under 16 has unlawfully provided us with personal data, Freedcamp will take the necessary steps to delete such information. Changes to Privacy Policy Freedcamp has the discretion to update this privacy policy at any time. When we do make changes, we will post a notification on the main page of our Site and send you an email. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications. Data Protection Officer Please contact Atanas Mahoney (atanas@freedcamp.com) for any questions related to our Privacy Policy. User Rights EU Users have certain statutory rights in relation to their personal data. Users may have the right to request or delete any personal information stored on Freedcamp. Please contact Atanas Mahoney (atanas@freedcamp.com) or support@freedcamp.com for assistance. Contact Information If you have any further questions regarding our Privacy Policies. You may also contact us a support@freedcamp.com or by mail at 3066 Foothill Rd Santa Barbara, CA 93105 (805)245-8713

Effective Date: 5/18/2018

Verification Method

Self-Assessment

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Freedcamp, Inc. at:

Igor Kryltsov
Mr
Freedcamp, Inc.
Australia
3066 Foothill Rd.
Santa Barbara, California 93105

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Freedcamp, Inc. to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Freedcamp, Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission