Privacy Policy

 

Last updated September 9th, 2024

 

This privacy notice for Frenos, Inc (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, safeguard and/or share (“process“) your information when you use our website, or any website of ours that links to this privacy notice, or engage with us in other related ways, including any sales, marketing or events (collectively the "Site"). Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. 

 

Information We Collect

A.   Personal Information Provided by You.
 
We collect personal information that you voluntarily provide to us when you register on the Site, express an interest in obtaining information about us or our products and services, when you participate in activities on the Site, or otherwise when you contact us. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site. Personal Information provided by you will depend on the context of your interactions with us the Site and the choice you make. The personal information we collect may include the following:
  • names
  • email addresses
  • job titles
  • phone numbers
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • billing addresses
  • debit/credit card numbers
We do not collect or process sensitive personal information

 

B.    Personal Information Collected Automatically.
 
We automatically collect some information using cookies and similar technologies, such as your Internet Protocol (IP) address, browser type and device characteristics, access times, and pages you have viewed when you access the Site. This information does not reveal your specific identity (e.g., your name or contact information). This information is primarily needed to maintain the security and operation of the Site, and for our internal analytics and reporting purposes.

 

C.    Mobile Device Data.
 
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

 

How We Use Your Information

We process your Personal Information for a variety of reasons, depending on how you interact with the Site. Having accurate information about you permits us to provide you with an optimized user experience. Specifically, we may use the information we collect via the Site to:

 

  • Create and manage your account.
  • Process your transactions and deliver our products and services.
  • Send you administrative information, such as confirmations, invoices, technical notices, updates, security alerts, support messages, as well information about features and enhancements, and respond to questions and comments.
  • Improve our website, products, and services.
  • Monitor and analyze usage and trends to improve your experience with the Site.
  • Protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

 

Disclosure of Your Information

We may need to share your personal information in the following situations:

 

  • Business Transfers. 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.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users (when applicable). 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 made available outside the Site in perpetuity. If you interact with other users of our Site and register for our Site 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.

 

Use of Cookies and Other Tracking Technologies

We and our service providers may use industry standard cookies and similar information gathering and tracking technologies (e.g., web beacons and pixels) to access and store certain types of information from your computer or mobile device when interacting with the Site. For purposes of this Privacy Notice, we will refer to cookies and similar technologies as "cookies". For more information about bookies, please visit: https://allaboutcookies.org.

 

A.    Cookie Policy. Cookies are small text files that may be placed on your Web browser when you visit our Site or when you view advertisements, we have placed on other Web sites. Cookies permit your browser to remember specific information which the Web browser can later retrieve and use.   When you close your browser, some cookies are stored in your web browser ("Session Cookies"), while others are stored longer which are activated each time you revisit the Site ("Persistent Cookies") We use a mixture of both types.

 

B.    Google Analytics. These are web analytics cookies, provided by Google, Inc., that are used to collect information about how visitors use the Site. We use the information to compile reports and to help us improve the Site. The cookies collect information including the number of visitors to the site, where visitors have come to the site from, and the pages they visited. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. We do not attempt to reconcile information collected via Google Analytics to identify an individual user. For more information about opting out of Google Analytics cookies please visit: https://tools.google.com/dlpage/gaoptout

 

C.    Hubspot. These are web analytics cookies, provided by Hubspot, Inc., that are used to collect information about how visitors use the Site. We use the information to compile reports and to help us improve the Site. The cookies collect information including the number of visitors to the site, where visitors have come to the site from, and the pages they visited. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Hubspot on servers in the United States. Huspot will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. We do not attempt to reconcile information collected via Hubspot to identify an individual user.
 
D.    Snitcher. These are web analytics cookies, provided by Snitcher, Inc., that are used to collect information about how visitors use the Site. We use the information to compile reports and to help us improve the Site. The cookies collect information including the number of visitors to the site, where visitors have come to the site from, and the pages they visited. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Snitcher on servers. Snitcher will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

 

Third-Party Websites

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Notice, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the Site.

 

Retention of Your Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When your personal information is no longer required, we will take the appropriate steps to have the personal information deleted, aggregated, or anonymized.

 

Data Security

We use appropriate administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, modify or misuse your information. You should only access the Site within a secure environment.

 

Children’s Privacy

The Site is not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently received personal data from a visitor under the age of 13 on the Site, we will delete the information from our records.

 

Your Privacy Rights

 A.   Depending on the jurisdiction in which you reside, you have the following rights regarding your personal information:

 

  • Right to Access. You have the right to request copies of your personal information
  • Right to Change or Correct. You have the right to request that we correct any information you believe is inaccurate.
  • Right to Deletion. You have the right to request that we delete your personal data, under certain conditions.
  • Right to Restrict Processing or Limit Use. You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
  • Right to Data Portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our contact information provided below.
 
 
B.   Account Information.
 
If you would at any time like to review or change the information in your account or terminate your account, you can:

 

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

 

C.   Reporting Unlawful Processing.
 
If you are located in the EEA or UK 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: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
 
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

D.   Withdrawing your consent. 
 
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided at the end of this Policy Notice.
 
 

Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

Specific Privacy Rights to California Residents

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 Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
 
 
A.   CCPA Privacy Notice.

The California Code of Regulations defines a “resident” as:
 
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
 
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
 
All other individuals are defined as “non-residents.”
 
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
 
 

Categories of personal information do we collect

We have collected the following categories of personal information in the past twelve (12) months:

 

Category

Examples

Collected
A.  Identifiers
Contact details, such as real name, alias, address, telephone or mobile contact number, unique personal identifier, online identifier, IP address, and account name
YES
B.  Personal Information categories listed in the Consumer Records statute
Name, contact information, education, employment, employment history, and financial information
NO
C.  Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D.  Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
E.  Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F.  Internet or other similar network activity
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G.  Geolocation data
Physical location or movements.
NO
H.  Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I.  Professional or employment-related information
Current or past job history or performance evaluations.
NO
J.  Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K.  Inferences drawn from other personal information
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
L.  Sensitive Personal Information
Government identifiers (such as social security numbers); an account login, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.
NO

 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

 

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our products and services and to respond to your inquiries.
 

How we use and share your personal information

More information about our data collection and sharing practices can be found in this privacy notice.
 
You may contact us by referring to the contact details at the bottom of this privacy notice.

 

Use of Personal Information.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
 
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
 
Frenos, Inc has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Frenos, Inc will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

 

Your rights with respect to your personal information

  • Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

 

  • Right to be informed — Request to know
Depending on the circumstances, you have a right to know:

 

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

  • Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your CCPA privacy rights.
 
  • Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.

 

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
 
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

 

To exercise these rights, you can contact us by referring to the contact details at the bottom of this Privacy Notice. If you have a complaint about how we handle your data, we would like to hear from you.

 

Changes to This Privacy Notice

We reserve the right to amend or update this Privacy Notice at our discretion and at any time. We will notify you of any changes by email or by posting the new Privacy Note on the Site and updating the “Last Updated” date at the top of this page. You are encouraged to review this Privacy Notice periodically to stay informed about how we are protecting your information.

 

Contact Us

 
If you have any questions, concerns or complaints about the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: privacy@frenos.io