Privacy Policy

FreeBalance Privacy and Cookie Policy

Effective Date: June 28, 2021

Introduction

FreeBalance Inc. and our affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes how we collect, use, disclose, and protect the personal information of our customers, leads and website users (“you”), describes the types of information we may collect from you or that you may provide when you visit this website (our “Website”), our practices for collecting, using, maintaining, protecting, and disclosing that information, and your rights with respect to the information. By Accessing or Using This Website, You Indicate That You Understand, Accept, and Consent to the Practices Described in This Policy.

We will only use your Personal Information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for the limited purposes outlined herein.

Privacy laws have defined Personal Information as any information about an identified or identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). Examples of Personal Information include name, email address, identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual.

This policy applies to information we collect, use, or disclose about our customers, leads and Website users:

  • on this Website;
  • in email, text, and other electronic messages between you and this Website; and
  • from third-parties.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third-party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not use our Website. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your Personal Information.

Information we collect about you

We collect and use several types of information from and about you, including:

  • Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, e-mail address, address and telephone number Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar and any other identifier we may use to contact you online or offline.

    We provide an opportunity for any user to unsubscribe or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails or by e-mailing to Integrity@FreeBalance.com.

  • Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.

  • Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How We Collect Information About You

We use different methods to collect your information, including through:

  • Direct interactions with you when you provide it to us, for example, by filling in forms, participating in surveys or corresponding with us by phone, email, or otherwise.

  • Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, and information collected through cookies.

  • Third parties or publicly available sources, such as public databases, social media platforms, and third-party data providers. We take steps to ensure that such third parties are legally permitted to disclose such information to us.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

  • Information that you provide by filling in forms on our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • Your search queries on the Website.

Information We Collect Automatically

As you navigate through and interact with our Website, we use cookies to collect certain information about your browsing actions, and patterns, including details of your visits to our Website and other communication data and the resources that you access and use on the Website.

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

FreeBalance uses cookies from Google Analytics to improve the functionality and performance of the Website. The information we collect automatically through Google Analytics is statistical data and does not include Personal Information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns and recognize you when you return to our Website.

To provide Website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on, to enable you to opt-out of Google’s programs.

FreeBalance does not use other automatic data collection technologies such as flash cookies, web beacons and pixel tags.

Information we collect from Third-Parties

As part of our marketing process FreeBalance may receive Personal Information from third-party lead providers, from public databases such as the IMF, World Bank, and the PEFA Secretariat, and when you follow us or engage with us on Twitter, Instagram or LinkedIn.

The Personal Information we receive from third-parties may include name, email address, telephone number, address, and information related to work history. FreeBalance ensures that any disclosure of your Personal Information by third-parties to FreeBalance is done so legally and that adequate data protection measures are used to protect your Personal Information. Where FreeBalance receives your Personal Information from a third-party we will notify you within one (1) month having regard to the specific circumstances in which your Personal Information was collected, or at the time of our first communication with you if such communication takes place less than one (1) month after your Personal Information was received by FreeBalance.

How and Why We Use Your Information

When you use the Website, we collect and process your Personal Information for various purposes. We have set out in the table below the various reasons why we process your Personal Information and the associated legal bases we rely upon to legally permit us to process your Personal Information:

Description of why FreeBalance processes your Personal InformationLegal basis
  • To present our Website and its contents to you.
  • To respond to your queries and requests.
  • To provide customer support.
  • To provide you with information, products, or services that you request from us.
  • To send you product updates, marketing communications and service information.
  • To understand how you access and use the Website to improve user experience.
  • To develop and improve our Website.
  • To manage our relationship with you.
  • Legitimate interest.
  • To analyze data, including through automated systems and machine learning to improve our services and your experience.
  • To conduct research and analysis.
  • For any other purpose with your consent.
  • Consent.
  • To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
  • Performance of a Contract; and
  • Compliance with legal obligations.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates which may only use your Personal Information for the purposes listed herein.

  • In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FreeBalance’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by FreeBalance about our customers and users is among the assets transferred.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FreeBalance, our customers, or others.

Choices about How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function
    properly.

  • Marketing. If you have received certain emails from us but no longer wish to have your email address used by FreeBalance to promote our own products or services, you can opt-out by clicking the unsubscribe link we have included in the email.

Transfers to Third-Parties

We may transfer Personal Information that we collect or that you provide as described in this policy to contractors or service providers who are bound by law or contract to protect your Personal Information and only use your Personal Information for the
purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and
the European General Data Protection Regulation (GDPR).

International Transfers

FreeBalance is a global company with affiliates and services providers located around the world. As a result, your Personal Information may be transferred to, stored at or processed in other countries which may not have equivalent privacy or data protection
laws. However, regardless of where your Personal Information is transferred, we will protect it in accordance with this Privacy Notice and applicable law.

By using our Website or submitting your Personal Information to us, you consent to this transfer, storage, or processing of your Personal Information.

Data Security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Children under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to or on the Website. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Integrity@FreeBalance.com.

Accessing, Correcting and Erasing Your Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

You have the right to review, verify, erase, restrict collection of and object to the collection of your Personal Information in certain circumstances by sending us an email at Integrity@FreeBalance.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Compliance Department at Integrity@FreeBalance.com.

If you feel we have infringed data protection laws, you have the right to file a complaint with a supervisory authority responsible for the collection of Personal Information.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you have the legal right to withdraw your consent at any time. To withdraw your consent, contact us at Integrity@FreeBalance.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page. We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Integrity@FreeBalance.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.