Last Updated: 31 Aug 2021
Frey Limited is committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected] .
What type of information do we collect?
In Short: We collect personal information that you provide to us such as name, address, email address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering at the Site and/or Related Services, such as subscribing to our mailing list, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Site and/or hosted by Frey Limited (such as posting messages on our online forums or entering competitions, contests or giveaways) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Site and/or Related Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data: We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor, and you should review its privacy policies and contact the payment processor directly to respond to your questions.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.
We automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes.
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public), marketing leads and search results and links, including paid listings (such as sponsored links).
How do we collect your information?
When you conduct a transaction on the Site, the Related Services or subscribe to our mailing list, as part of the process, we collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated below only.
How do we use your information?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Site and/or Related Services for a variety of business purposes as described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual Reasons”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive for the purposes listed below:
If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “Social Logins” for further information.
We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “Your Privacy Rights” below).
We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Sites.
We post testimonials on our Site that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
We may use your information to administer prize draws and competitions when you elect to participate in those events and/or competitions.
We may use your information to request feedback and to contact you about your use of our Site and/or Related Services.
We may use your information as part of our efforts to keep our Site and/or Related Services safe and secure (for example, for fraud monitoring and prevention).
We may use your information in order to enable user-to-user communications with each user’s consent.
If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site and/or Related Services, products, services, marketing and your experience.
Will your information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We only share and disclose your information in the following situations:
We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data about how you interact with the Site over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may share your information with our business partners to offer you certain products, services or promotions.
We may disclose your personal information for any other purpose with your consent.
When you share personal information (for example, by posting comments, contributions or other content to the Site) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity. If you interact with other users of our Site and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Site, and view your profile.
How do we communicate with you?
We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our Terms & Conditions, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.
How do we store, use, share and disclose your personal information?
Our website is hosted on the WooCommerce platform. WooCommerce provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through WooCommerce’s data storage, databases and the general WooCommerce applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by WooCommerce and used by our website adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
What is our stance on third-party websites?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Site and/or Related Services.
How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
What are your privacy rights?
In Short: In some regions, such as the European Economic Area (“EEA”), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA), you have certain rights under applicable data protection laws. These may include, but not limited to, the right:
To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
As we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the EEA and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
You may, at any time, review or change the information in your account or terminate your account by:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms & Conditions and/or comply with legal requirements.]
Cookies and similar technologies
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:
Do California or U.S. residents have specific privacy rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
The CAN-SPAM Act applies to all legal persons (i.e., both natural persons and businesses) in the U.S. and those sending emails from abroad to a recipient who is in the U.S. In short, this law covers all commercial messages, i.e., any email with the goal of advertising or promoting products or services and give a U.S. recipient the right to have emails stopped from being sent to them with penalties for violations.
For the purpose of this policy, please note that we collect your email address in order to:
To comply with the CAN-SPAM Act, we agree to the following:
How can you withdraw your consent?
If you are on our mailing list and you do not wish to receive any communications anymore, you can unsubscribe by clicking the “unsubscribe” button at the bottom of our emails.
If you don’t want us to process your data anymore, please contact us at [email protected].
How can you contact us about this policy?
If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact us at:
Email: [email protected]
Address: Frey., G04, 9 Queen’s Road, Central, Hong Kong Island, Hong Kong.
If you have any questions or comments about this policy, you can also email us at [email protected].