PRIVACY POLICY

PART I- GENERAL STATEMENT

Freely Technology Inc. (“Freely”, “our”, ”us”, “we”), respects your privacy and is committed to protecting it through compliance with this Privacy Policy. This Privacy Policy describes how Freely may collect, use, secure, safeguard, and share the information you provide us and the information we collect in the course of operating our business. This includes your use of Freely websites where this Privacy Policy is posted, as well as any products, services, software, tools, platforms, databases, solutions, equipment, applications, features and functionality offered on or through a website or mobile application (collectively, the “Product”) operated by Freely. Accordingly, before registering, submitting any content or personal information, or otherwise using our Product, please make sure that you read this entire Privacy Policy.

By accessing or otherwise using our Product, you consent to the terms of this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with the provisions of this Privacy Policy, do not use or access our Product or otherwise provide us with any of your personal information.

PART II- COLLECTION OF PERSONAL INFORMATION

Our Products may collect personal and non-personal data (collectively, “User Data”). To accomplish any of the purposes listed below, Freely may combine personal information, automatic information, and non-personal information collected through the use of our Products. The User Data we collect includes, but without limitation:

Personal data refers to organized information that allows us to identify and contact you. This includes personal content and other information you provide when you use our products. Namely, inter alia, email address, name, zip/postal code, phone number, address and unit, License plate data, payment-related information, or any content that can be used for identification.
License plate data refers to information associated with the license plate of a registered vehicle. This includes the image of the license plate, license plate number, image of the vehicle, vehicle information (include, without limitation, vehicle make, vehicle model, vehicle color, vehicle specification). Additionally, images of the vehicle and access to records may contain environmental clues of where the vehicle is used, or has previously been.
Information and data about your use of our products. This includes the functionality you used, the log of your usage, access records, device information and user interaction record.
We also collect information from third parties. This includes information from advertisers, contractors, clients and developers. These third parties, or partners, may provide your information to us for registration, management or analytic purposes. For example, a parking management team may inform us about your activities and information if they are using our parking management solution or other Products.
Payment-related information will be collected if you are making payment or completing a transaction with our Product. This may include information regarding your credit/debit card, online payment method and authentication and billing/shipping address.
Feedback and communication content from users and clients may be collected for any purpose.

PART III- WHY WE NEED TO COLLECT DATA AND USER INFORMATION

Freely collects, processes, and retain the User Data from various Product channels for a multitude of purposes, namely:

Optimizing and developing the algorithm, functionality, performance of our products and service;
Engaging in case study, research, and analysis relating to our products and service;
Delivering the products and services your ordered from us;
Billing and collecting payment for the products and services;
Providing service or delivering product to the user, by registering, authenticating, and confirming your identity or personal information;
Obtaining feedback and understanding your need for any customization need on our product or services;
Complying legal obligation and regulation;
Processing payment, subscription, invoice; and
Communicating with you.

PART IV- SECURITY AND CONFIDENTIALITY

Freely takes commercially reasonable steps to help protect and secure User Data. In general, Freely and our subsidiaries, affiliates and partners will handle all User Data on a confidential basis and make all reasonable efforts to keep such information non-accessible to the general public. In the event Freely enters into a contract or agreement with a third party, Freely will make all reasonable efforts to ensure the party/parties will handle User Data in a confidential manner and non-accessible to the general public.

However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be completely secure. Please note that we cannot ensure or warrant the security of any information we collect. As such, please use our Product and provide us with your information at your own risk.

PART V- DATA ANONYMIZATION

In order to protect your privacy, the User Data may be required to be aggregated or anonymized upon sharing. “Aggregated” or “Aggregated Information” refers to combining and expressing information in a summary form, in such a way that personal User Data cannot be reasonably determined. For example, we may describe an area by its demographic, instead of disclosing the personal information of the tenants in the area. “Anonymization” or “Anonymize” refers to irreversibly altering the User Data into non-personal data by encrypting, removing, de-identifying, and/or aggregating. Such altered data will not contain any personally identifiable information.

PART VI- DISCLOSURE OF INFORMATION

Freely will not disclose the information provided by you, except under the following circumstances:

If it is necessary to provide the service and delivery of the Product you have ordered;
If it is necessary to enforce our right under any applicable terms and conditions or agreement;
If it is required by law and regulation or in response to any subpoena or search warrant;
In the aggregated data, in such a way that your personal data will not be reasonably determined for research, report, business develop purposes;
If it is necessary to maintain, safeguard and preserve all the rights and property of Freely; and
For business developing purposes, after we de-identify and anonymize the information, we may disclose such information for marketing, financial, analytical and research purposes.

PART VII- SHARING INFORMATION WITH THIRD PARTIES

We may share the User Data to Freely’s companies, or affiliates for any purposes. Furthermore, we may share User Data with third parties as follows:

Advertisers: Freely may allow third parties to use Cookies through our Product to collect the same type of information for the same purposes as Freely does. Additionally, Freely only shares information that is not personally identifiable information with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address) to facilitate the display of targeted advertising. You may be able to limit our sharing of some of this information through your device settings.
Service Providers: We may rely on third party providers to support or provide features and options that are available through our Products. We may also rely on third party providers to perform certain services for us in connection with your use of our Products, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, marketing of Freely Products and other functions. We may share information from or about you with these third-party providers so that they can perform their services or complete your requests. These third-party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third-party providers may also share this information with their subsidiaries, joint ventures, affiliates, partners or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third-party providers, while preserving the look and feel of our product. In such cases, please note that the information you provide is being provided to the third party.
Aggregate Information: We may share user non-personal information in the aggregate with third parties, such as advertisers, brand managers and content distributors for any purposes. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements.
Business Transfers: We may share information from or about you with our subsidiaries, affiliates, partners, joint ventures or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires Freely or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.
Investigations: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (1) is reasonably necessary to comply with federal, state, or local legal process and legally binding law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding or other legal process served on us; (2) is helpful to prevent, investigate, or identify possible wrongdoing in connection with our Product; or (3) protects our rights, reputation, property, or that of our users, affiliates, clients, partners, or the public. If you flag or otherwise complain to Freely about content available through our Products, we may share the substance of your complaint with the contributor of that content or product in order to provide an opportunity for the contributor to respond.
Links: Freely Products may contain links to unaffiliated third-party services. Except as set forth herein, we do not share your personal information with them and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third-party services.
Third Party Accounts: If you sign up for, or log into, Freely using a third party service like Facebook or Google, or link your Freely account to your account with a third party service like Facebook or Twitter, we may receive information about you from such third party service. If you post content to a third-party service through the Product, that third party service will also receive that content, which will be visible to anyone that has access to it through that third-party service.

PART VIII- RETENTION OF DATA

Freely will retain the User Data only for as long as necessary to fulfill the purpose of collecting such data or information. Once the User Data is no longer required for above purposes, Freely will destroy, de-identify and anonymize said data.

PART IX- COOKIES

Cookies are files that contain information about your browsing activities that allow the website to personalize your visit, remember your preference, provide faster loading time, and so forth. When you visit a website your device will automatically store the Cookie within the browser, this is primarily used for developing your browse experience. However, Cookies are not essential and you can opt-out any point by changing the setting of your browsers.

PART X- CHANGES TO THE PRIVACY POLICY

This statement is in compliance with Canadian privacy laws and regulations and may be subject to update. We will notify you by email or by posting a notice on our website prior to the effective date of the changes and your continued use of the Service and/or Parking System after the effective date of the changes shall constitute your acceptance of such changes.

PART XI- CONTACT US

Any questions, comments or concerns relating to this Privacy Policy, and any requests to correct or access Personal Information collected during your use of the Products, please reach us by email: info@freely.io