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Privacy Policy


EFFECTIVE DATE: 18.11.2022


  1. 1. GLOSSARY

    1. 1.1. Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    2. 1.2. The Subject of Personal Data means User whose Personal Data the Company obtains in connection with providing Service. 
    3. 1.3. The Company means a company "Limited Liability Company Bardis”, registered under the laws of Kyrgyzstan, registered address: Kyrgyzstan, Bishkek, Chui Ave., 182, registration number: 216658-3301-ООО, Taxpayer Identification Number: 00604202310249, and its affiliated companies, which is the developer and the owner of the Service. 
    4. 1.4.  The Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
    5. 1.5. The Cookies means small files that are placed on User’s computer, mobile device or any other device by a website, containing the details of User’s browsing history on the Service among its many uses.
    6. 1.6. The Data Controller, for the purposes of the GDPR (General Data Protection Regulation), means the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
    7. 1.7. The Payment Service means payment systems Wise (https://wise.com/), Stripe (https://stripe.com/en-nl), FindexIQ (https://psp.findexiq.com/). To use the Site, the User must accept:
  2. 1.7.1. Wise Terms of Use (https://wise.com/terms-and-conditions), Wise Privacy Policy (https://wise.com/gb/legal/privacy-policy-eea), Wise Cookie Policy (https://wise .com/gb/legal/cookie-policy) and other Wise documents necessary to work with the Wise;
  3. 1.7.2.  Stripe Terms of Use (https://stripe.com/en-nl/legal/ssa), Stripe Privacy Policy (https://stripe.com/en-nl/privacy), Stripe Cookie Policy (https://stripe .com/en-nl/legal/cookies-policy) and other Stripe documents necessary to work with the Stripe;
  4. 1.7.3.  FindexIQ Terms of Use (https://psp.findexiq.com/offer), FindexIQ Privacy Policy (https://psp.findexiq.com/policy), FindexIQ Cookie Policy (https://psp.findexiq.com/cookies ) and other FindexIQ documents necessary to work with the FindexIQ. 
    1. 1.8. The Account means a Service page to which the User gains personal access after completing registration and/or authorization on the Service.
    2. 1.9. The Personal Data/Personal Information/Data any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    3. 1.10. The Policy means this Privacy Policy at: https://frieslancer.com/page/privacy-policy.
    4. 1.11. The Registration means the process of entering the registration information of the User, after which the User gets the opportunity to use the functionality of the Service in accordance with the Agreement.
    5. 1.12. The Service means the internet resource consisting of a set of (a) computer programs (software code running on a computer) and (b) the information (content) placed in them by the Company and/or Users. The Service is maintained in an information system that provides the access to the aforesaid information in Internet when addressed by the domain name https://frieslancer.com.
    6. 1.13. The Task means an invitation to make offers posted on the Service by the Client and addressed to the Contractors.
    7. 1.14. The User means a natural person legally capable of accepting this Agreement, who has gained access to the Service and the ability to use it within the limits established by the Agreement, acting on his/her own behalf and in his/her own interests.
    8. 1.15. The Verification Service means system “SumSab” (https://sumsub.com/), which provides the services of Users’ verification. The User must accept the SumSab Terms of Use (https://sumsub.com/terms-of-use), the SumSab Privacy Policy (https://sumsub.com/privacy-notice/), the SumSab Cookie Policy (https://sumsub.com/cookie-policy/) and other SumSab’s documents necessary to use its services.
    2. 2.2. The Company values User’s right to privacy and strives to protect User’s personal data in accordance with applicable data protection legislation in each relevant country including in particular the EU General Data Protection Regulation (“GDPR”) and its national implementing legislation as well as any UK GDPR regulations. 
    3. 2.3. This Privacy Policy describes the Company’s policies and procedures on the collection, use and disclosure of User’s information when the User uses the Service and tells the User about the User’s privacy rights and how the law protects the User. The Company uses User’s Personal data to provide and improve the Service. 
    4. 2.4.       The Company will comply with the data protection principles by making sure that all User’s personal data is:
  8. 2.3.1. Fairly and lawfully processed in a transparent manner;
  9. 2.3.2. Processed for specific and limited purposes;
  10. 2.3.3. Adequate, relevant and not excessive and limited to purpose for which Company uses User’s personal data;
  11. 2.3.4. Accurate and kept up to date;
  12. 2.3.5. Not kept longer than necessary;
  13. 2.3.6. Processed in accordance with User’s rights to information, correction or deletion;
  14. 2.3.7. Protected by technical and organizational safeguards to ensure the security of User’s personal data;
  15. 2.3.8. Not transferred to countries outside the European Economic area unless the country to which User’s
  16. 2.3.9. Personal Data is to be transferred has adequate protection for User.
  17. 2.5. This Policy applies from 18.11.2022. 
  18. 2.6. The User shall read this Policy carefully to understand Company’s policies regarding Personal Data.
  19. 2.7. By using the Service, the User gives his/her agreement to the Company’s processing any personal data the Company may have as described in this Policy. If the User does not agree with the terms and conditions of this Policy, then the User should reject using the Service.
  20. 2.8. The Service does not address anyone under the age of 16. The Company does not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided the Company with Personal Data, please contact the Company at the email info@frieslancer.com. If the Company becomes aware that the Company has collected Personal Data from anyone under the age of 16 without verification of parental consent, the Company will take steps to remove that information from the servers. If the Company needs to rely on consent as a legal basis for processing User’s information and User’s country requires consent from a parent, the Company may require User’s parent's consent before the Company collects and uses that information. 
  21. 2.9. This Policy applies only to the Service. The Company is not responsible for privacy practices within any other websites. The User should always be aware of this when the User leaves the Service and the Company encourages the User to read the privacy statement on any other website that the User visits. The Company may embed external content from third-party websites, including cookies. This content is not published on the Service. It is delivered using devices and services from third party sites that can be inserted into the Service such as media players, RSS feeds and widgets. These websites may use cookies. Their content is subject to the privacy policy of the relevant third-party provider and not the Company’s.
  22. 2.10. The Terms of Use (https://frieslancer.com/page/terms-of-service) describe the conditions under which the User uses the Service and the Company provides the Service and are an integral part of this Policy. 
    1. 3.1. Personal Data is any information which could potentially make an individual identifiable and can include, but may not be limited to, User’s name, address, date of birth, email address and IP address.
    2. 3.2. While using Service, the Company may ask the User to provide the Company with certain personally identifiable information that can be used to contact or identify the User. Personally identifiable information may include, but is not limited to:
  26. 3.2.1. Email address;
  27. 3.2.2. First name and last name;
  28. 3.2.3. Address, State, Province, ZIP/Postal code, City;
  29. 3.2.4. Content User provides (such as photos, articles, assessments, information, personal details);
  30. 3.2.5. Qualifications, CV, references, education; 
  31. 3.2.6. Personal Data posted by the User in feedback forms and/or other uses of the Service (e.g., if the User contacts the Company’s customer care team, the Company collects Data the User gives the Company during the interaction);
  32. 3.2.7. Usage Data. Usage Data is collected automatically when using the Service. Usage Data may include information such as User’s Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Company’s Service that User visits, the time and date of User’s visit, the time spent on those pages, unique device identifiers and other diagnostic data. When the User accesses the Service by or through a mobile device, the Company may collect certain information automatically, including, but not limited to, the type of mobile device User uses, User’s mobile device unique ID, the IP address of User’s mobile device, geolocation information, User’s mobile operating system, the type of mobile Internet browser the User uses, unique device identifiers and other diagnostic data. The Company may also collect information that User’s browser sends whenever the User visits the Service or when the User access the Service by or through a mobile device;
  33. 3.2.8. information about the User that the Company receives from its partners (for example, from the Payment Operator and Verification Service) in accordance with the terms of agreements concluded between the User and the relevant partner, and agreements concluded between the Company and the Partner;
  34. 3.2.9. Personal Information received from other sources, such as public databases, social media platforms, as well as from other third parties. Other Data about the User that the Company receives from the Company’s partners in accordance with the terms of agreements concluded between User (the Subject of Personal Data) and the relevant partner, and agreements concluded between the Company and the partner;
  35. 3.2.10. other information relating to the User as an identified or identifiable natural person.
  36. 3.3. The Company may collect information about the User in various ways: 
  37. 3.3.1. Directly in connection with an actual or potential relation with the Company;
  38. 3.3.2. Directly from User when the User visits and uses the Service;
  39. 3.3.3. From publicly available sources;
  40. 3.3.4. When the User visits the Service by means of cookies. 
  41. 3.4. The Company may use third-party services for payment processing (e.g. payment processors). The Company will not store or collect User’s payment card details. That information is provided directly to the Payment Operator whose use of User’s personal information is governed by their Privacy Policy.  
  42. 3.5. The Company does not collect, process, or store personal data necessary for User verification for the purpose of making payouts to the User’s card. Such personal data is collected, processed and stored by the Verification Service  and can include but is not limited to:
  43. 3.5.1. Verification of ID document;
  44. 3.5.2. Verification of residence address.
  45. 3.6. The Company does not verify the Personal Information provided by the User, except as provided for in this Policy, Terms, and cannot judge its reliability, as well as whether the User has sufficient legal capacity to provide Personal Information. Nevertheless, the Company assumes that the User provides reliable and sufficient Personal Information, and also updates it in a timely manner.
  46. 3.7. The Company does not purposefully collect sensitive Personal Information (such as racial origin, political views, health information).
  47. 3.8. The Company collects Data through cookies and similar technologies (see the “Tracking Technologies and Cookies”).
    1. 4.1. In general, Personal Information the User submits to the Company is used either to respond to requests that the User makes, aid the Company in serving the User better, or market the Company Service. The Company uses User’s Personal Information in the following ways:
  51. 4.1.1. To provide and maintain the Service, including to monitor the usage of Service;
  52. 4.1.2. To manage User’s account: to manage registration as a User of the Service. The Personal Data the User provides can give the User access to different functionalities of the Service that are available to User after registration;
  53. 4.1.3. For the performance of the Terms of Use;
  54. 4.1.4. To contact the User: by email, or other equivalent forms of electronic communication, such as push notifications regarding updates or informative communications related to the functionalities, products of Service, including the security updates, when necessary or reasonable for their implementation;
  55. 4.1.5. To provide the User: with news, special offers and general information about other services and events which the Company offers unless User has opted not to receive such information; 
  56. 4.1.6. To protect the Service: the Company may use User’s Personal Information as part of efforts to keep the Service safe and secure (for example, for fraud monitoring and prevention);
  57. 4.1.7. To manage User’s requests: to attend and manage User’s requests to the Company;
  58. 4.1.8. To enable Users’ communications: the Company may use User’s Personal Information in order to enable User-to-User communications with each User's consent;
  59. 4.1.9. For business transfers: the Company may use User’s information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about the Service Users is among the assets transferred;
  60. 4.1.10. For other purposes: the Company may use User’s information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Company’s promotional campaigns and to evaluate and improve Company’s service, products, services, marketing and User’s experience.
  61. 4.2. The Company may share User’s Personal Information in the following situations:
  62. 4.2.1. With service providers: the Company may share User’s Personal Information with service providers to monitor and analyze the use of Service to contact the User;
  63. 4.2.2. For business transfers: the Company may share or transfer User’s Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Company’s business to another company;
  64. 4.2.3. With affiliates: the Company may share User’s Data with Company’s affiliates, in which case the Company will require those affiliates to honor this Policy. Affiliates include any other subsidiary company, joint venture partners or other companies that the Company controls or that are under common control with the Company;
  65. 4.2.4. With law enforcement / when required by law: the Company may disclose User’s Personal Information where the Company is legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process. The Company may disclose User’s Personal information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person;
  66. 4.2.5. With Third-Party Advertisers: the Company may use third-party advertising companies to serve ads when the User visits the Service. These companies may use information about User’s visits to the Service that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to User; 
  67. 4.2.6. With business partners: the Company may share User’s Data with Company’s business partners (e.g. Payment Operator) to offer the User certain products, services or promotions;
  68. 4.2.7. With other Users: when the User shares Personal Information or otherwise interact in any public area the Company provides with other Users, such information may be viewed by all Users and may be publicly distributed outside;
  69. 4.2.8. With User’s consent: the Company may disclose User’s Personal Information for any other purpose with User’s consent.
  70. 4.3. The Company may disclose User’s Personal Data in the good faith belief that such action is necessary to: 
  71. 4.3.1. Comply with a legal obligation;
  72. 4.3.2. Protect and defend the rights or property of the Company;
  73. 4.3.3. Prevent or investigate possible wrongdoing in connection with the Service;
  74. 4.3.4. Protect the personal safety of Users of the Service or the public;
  75. 4.3.5. Protect against legal liability.
  76. 4.4. In order for the Company to provide the Service to the User, it is essential that the Company is able to collect and use the information as described in this Policy. This means that data collection is largely necessary for fulfilling the relationship the Company has with the User, and where that is not the case, the Company has a legitimate interest in collection User’s Personal Information or the Company needs this information to comply with legal and regulatory obligations. 
  77. 4.5. The Company may receive testimonials and comments from Users who have had positive experiences with the Service. The Company may publish such content. When the Company publishes this content, the Company may identify Users by their first and last name. The Company obtains the User's consent prior to posting this information along with the testimonial.
  78. 4.6. If the User chooses to provide the Company with Personal Information that may be considered “special” or “sensitive” in certain jurisdictions, the User is consenting to the Company’s processing of that Personal Information in accordance with this Policy. 
  79. 4.7. The Company may collect, use, store, sharing, profiling, review, publish (where it relevant) information applying automated processing techniques and, in some instances, conduct manual (human) according to Company’s purposes specified above.
  80. 4.8. The User does not have a statutory obligation to provide the Company with any information, but the User may have a contractual obligation to do so in accordance with the Terms of Use (https://frieslancer.com/page/terms-of-service); in the absence of such information, the Company may not be able to provide the Service, in whole or in part.
  81. 4.9. When the Company processes User’s Personal Data on the basis of explicit consent, please note that the User has the right to withdraw that consent at any time. The User may do so by sending a request to info@frieslancer.com. 
    1. 5.1. The Company and Service use Cookies and similar tracking technologies to track the activity on the Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Service. The technologies the Company uses may include:
  85. 5.1.1. Cookies or Browser Cookies. A cookie is a small file placed on User’s device. User can instruct User’s browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if the User does not accept Cookies, the User may not be able to use some parts of the Service. Unless the User has adjusted User’s browser setting so that it will refuse Cookies, the Service may use Cookies. 
  86. 5.1.2. Flash Cookies. Certain features of the Service may use local stored objects (or Flash Cookies) to collect and store information about User’s preferences or User’s activity on the Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
  87. 5.1.3. Web Beacons. Certain sections of the Service and Company’s emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
  88. 5.2. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on personal computer or mobile device when User goes offline, while Session Cookies are deleted as soon as User closes web browser. The Company uses both Session and Persistent Cookies for the purposes set out below:
  89. 5.2.1. Necessary / Essential Cookies Type: Session Cookies; Administered by: Company; Purpose: these cookies are essential to provide User with services available through the Service and to enable User to use some of its features. They help to authenticate Users and prevent fraudulent use of User accounts. Without these cookies, the services that User has asked for cannot be provided, and the Company only uses these cookies to provide User with those services.
  90. 5.2.2. Cookies Policy / Notice Acceptance Cookies. Type: Persistent Cookies; Administered by: Company; Purpose: these cookies identify if Users have accepted the use of cookies on the Service.
  91. 5.2.3. Functionality Cookies Type: Persistent Cookies; Administered by: Company; Purpose: these Cookies allow the Company to remember choices User makes when use the Service, such as remembering login details or language preference. The purpose of these cookies is to provide the User with a more personal experience and to avoid having to re-enter User’s preferences every time the User uses the website.
  92. 5.3. If the User would like to opt out, or restrict the use of cookies, the User is able to adjust the settings in Internet Browser to do this. Exactly how this is done will depend on which browser used for access to the Internet. Each browser has its own variation on how this can be achieved, but it is usually under ‘Settings’ which can be found at the end of the Search bar. 
  93. To get more detailed information about cookie management with specific web browsers, please find it on the browsers' respective websites:
    1. 5.3.1. For Google Chrome, please refer to these instructions;
    2. 5.3.2. For Firefox, please look up here;
    3. 5.3.3. For Safari, please visit this page;
    4. 5.3.4. For Internet Explorer, please refer to these instructions.
    5. 5.4. If the User does not accept cookies, however, the User may not be able to use all portions of the Service or all functionality of the Service.
    6. 5.5.   Cookies don’t collect things like name or email address. This is a random sequence of numbers and letters which the Company can use to link information collected by the cookies back to the User without the cookies collecting User’s name or email address. This enables the Company to identify User’s device so that the Company can improve User’s experience and make sure settings are remembered correctly. This allows the Company to use the information collected by the cookies to understand more about User’s use of Service, and in time, help make the Service more relevant to Users.
    1. 6.1. The Company may transfer to and store the Personal Information about User in countries other than the country in which the Personal Information originally was collected, including the United States, Canada or other destinations outside the EEA (the European Economic Area) and the United Kingdom.  
    2. 6.2. Those countries may not have data protection or other laws as comprehensive as those in User’s country in which the User provides the Data. When the Company transfers User’s Data to other countries, the Company will protect the Data as described in this Policy and comply with applicable legal requirements providing adequate protection for the transfer of Data to countries outside the EEA and outside the United Kingdom. The Company will take all necessary measures to protect User’s Personal Information in accordance with this Policy and applicable law. 
    3. 6.3. If the User is located in the EEA or the United Kingdom, the Company will only transfer User’s Personal Data if:
  97. 6.3.1. the country to which the Personal Data will be transferred has been granted a European Commission adequacy decision (in the case of transfers out of the EEA) or such country has been deemed to provide an adequate level of protection for personal data by the UK Government (in the case of transfers out of the UK); or 
  98. 6.3.2. the Company has put in place appropriate safeguards in respect of the transfer, for example the Company has entered into EU standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority.
  99. 6.4. The User may request more information about the safeguards that Company has put in place in respect of transfers of Personal Data by contacting the Company as described in “Contact Details”.
  101. 7. USER’S RIGHTS
    1. 7.1. Under certain circumstances, the User may have a number of privacy rights concerning the use, storage, and processing of User’s Personal Data (e.g., the right to delete User’s Data).
    2. 7.2. The User has the following rights:
  102. 7.2.1. To be informed. This policy is one of ways in which the Company informs how and why the Company processes User’s Data;
  103. 7.2.2. Of access. All Users have the right to quest access to all of the data the Company holds on them, the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; other information specified in art. 15 GDPR. Any User’s requests received will be reviewed and responded to within one calendar month of receipt of the request. Most requests will be fulfilled free of charge, however, the Company reserves the right to charge a reasonable administration fee for any requests deemed to be excessive, unfounded or repetitive;
  104. 7.2.3. Of rectification. Should the User find that any data the Company holds about the User is incorrect, the User can ask the Company to correct it and the Company will investigate and respond within one calendar month of receipt of the request;
  105. 7.2.4. Of Erasure. The User can ask for User’s Personal Data to be erased permanently. All such requests will be responded to within one calendar month of the receipt of a request. Please note that, whilst the Company will always endeavour to fulfil requests, there may be some instances when this is not possible due to legal or regulatory reasons. The Company will always provide a full explanation in any such instances;
  106. 7.2.5. To restrict processing. If the User does not wish for User’s data to be erased, the User may ask for it to be restricted so that the Company continues to hold it but not process it or use it in any way – the Company would essentially ‘archive’ User’s data. This is only applicable in certain circumstances; however the Company will look at all requests and respond within one calendar month of the receipt of a request;
  107. 7.2.6. To data portability. All electronically held data can be transferred to another company in a structured, commonly used and machine-readable format on request. Please note that this will only include the data User has provided to the Company and not any ancillary data produced as a result of the services the Company have created during the provision of Company’s services or where that data includes information regarding a third party. All requests for moving data will be responded to within one calendar month of a request being received;
  108. 7.2.7. To object. The User can object to Company’s processing data for the purposes of marketing, scientific/ historical research and statistics, or legitimate interests or in the performing of a task in the public interest /exercise of official authority (including profiling). All such requests shall be responded to within one calendar month 
  109. 7.2.8. Rights related to automated decision making, including profiling. The GDPR sets out specific rights in relation to automated decision making. Please note that the Company does not use any form of automated decision making system whilst processing User’s data;
  110. 7.2.9. To Opt-Out. Where the Company processes User’s Data for direct marketing purposes, the User may at any time object to the processing thereof or withdraw consent thereto. The User may therefore at any time after consenting to the Company sending marketing communication, change preferences. The User may unsubscribe to Company’s newsletters, change User’s settings in private areas (if applicable) or send the Company a request to opt-out of Mailings.
  111. 7.2.10. To complain. The User has the right to raise a complaint regarding the processing of User’s data or Company’s response to a request under the above rights. As part of this, the User also has the right to escalate User’s complaint to a supervisory authority. The User can find information about User’s data protection regulator in the EEA here, and in the United Kingdom here.  
  112. 7.3. Users have the right to withdraw Users’ consent to Company’s processing data at any time by sending an email to the address: legal@frieslancer.com.
  113. 7.4. In respect of any of the rights indicated above, if the User would like to make a request, require further information, or have a complaint regarding Company’s processing of User’s data, the User shall send an email to info@frieslancer.com.
  114. 7.5. The Company may reject requests, including if the Company is unable to authenticate the User, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else.
  118. 8.1. Personal Data will always be held for the minimum amount of time required. This will depend on a number of factors, such as the terms and length of a contract or a relevant law or regulation based on law.
  119. 8.2. If the User decides to stop using Service, the User can close User’s account and account will stop being visible to other Users. Note that the Company will close User’s account automatically if User is inactive for a period of one year and in other cases specified in Terms of Use https://frieslancer.com/page/terms-of-service. After User’s account is closed, the Company will delete User’s Personal Information, as laid out below:
  120. 8.2.1. To protect the safety and security of Company’s Users the Company implements a safety retention window of three months following account closure, or nine months following an account ban. During this period, the Company keeps User’s Personal Information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of Personal Information during this safety retention window is based on Company’s legitimate interest as well as that of potential third-party victims.
  121. 8.2.2. Once the safety retention window elapses, the Company deletes User’s Personal Data and only keeps limited Personal Information for specified purposes, as laid out below:
  122. maintain Personal Information on the basis of Company’s legitimate interest where there is an outstanding or potential issue, claim or dispute requiring the Company to keep Personal Information (in particular if the Company receives a valid legal subpoena or request asking the Company to preserve Data (in which case the Company would need to keep the Data to comply with legal obligations) or if Data would otherwise be necessary as part of legal proceedings);
  123. maintain limited Personal Information on the basis of Company’s legitimate interest: the Company keeps customer care records and supporting data as well as imprecise location of download for five years to support customer care decisions, enforce rights and enable the Company to defend itself in the event of a claim; account data for one year in anticipation of potential litigation, for the establishment, exercise or defence of legal claims;
  124. maintain limited Data to comply with legal data retention obligations: in particular, the Company keep “traffic data” / logs for one year to comply with legal data retention obligations. The Company keeps records of User’s consents given for five years to evidence Company’s compliance with applicable law.
  125. 8.3. In order to meet Company’s professional and legal requirements, to establish, exercise or defend its legal rights, and for archiving and historical purposes the Company needs to retain Personal Information for significant periods of time. 
  129. 9.1. Only Company’s authorized personnel and the third parties described in this Policy are provided access to Personal Data. These employees and third parties have agreed to maintain the confidentiality of this Data.
  130. 9.2. The Company will implement the necessary administrative, technical and organizational measures for ensuring a level of security appropriate to the specific risks that the Company has identified. The Company protects User’s Personal Data against destruction, loss, alteration, unauthorized disclosure of or access.
  131. 9.3. The security of User’s Personal Data is important to the Company, but the User shall remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While the Company strives to use commercially acceptable means to protect User’s Personal Data, the Company cannot guarantee its absolute security.
  135. 10.1. The Company may update Policy from time to time. 
  136. 10.2. The Company will notify the User of any changes by posting the new Policy on page https://frieslancer.com/page/privacy-policy. 
  137. 10.3. The User is advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 
  141. 11.1. If the User has questions or comments about this Privacy Policy or wish to contact the data protection officer, the User has the following options: 
  142. 11.1.1. email the Company katarzyna.c@crowe.cz.
  143. 11.1.2. by post: Kyrgyzstan, Bishkek, Chui Ave., 182.
  144. 11.2. If User has any further questions or comments about the Company or the Company’s policies email the Company at info@frieslancer.com or contact the Company by post at: Kyrgyzstan, Bishkek, Chui Ave., 182.