The data controller is:
Frederiksholms Kanal 30,
1220 Copenhagen (Denmark)
CVR no. 37074462
(“Freemi” or “Freemi app”).
Personal data which we collect
We collect personal data from you and any device (including mobile devices) that you use when you: use our services, set up a user account with us, give us information in a web form, update or add information about your user account, participate in the community’s content, chats or when you correspond with us in any other way.
Some of these personal data are necessary to submit in order to set up a user account with us. Submitting all other personal data is voluntary but may be necessary in order to use our Services, e.g. the data that are necessary to publish a free post.
We collect personal data as described below.
Personal data which you give us when you use our Services or set up a user account with us:
- Data such as your first name, your email address, your age and gender when you set up a user account with us.
- Data such as your full name, your address and phone number when you win prizes from competitions on Freemi.
- Other content which you generate or that is linked to your user account and your use of our services such as your use of the following central website features: Free feed, Post thing, Messages, Chat, Profile, Benefits and Help, Rules, Support and Feedback features.
- Data such as interests, beliefs and suggestions for improvement etc. which you submit when you use our services, including e.g. in a web form, when you update or add data about your user account, participate in chats and other correspondence or when you otherwise communicate with us about our Services.
- Further information which we are required or entitled to process in accordance with national legislation, among other things in order to be able to authenticate or identify you or verify the data that we have collected.
Personal data which we automatically collect when you use our Services or set up a user account with us:
- We collect data about your interaction with our Services, your content preferences and your communication with us. These are data that we receive from devices (including mobile devices) that you use when you access our services. These data may include e.g. the following: device ID or unique identifier, device type, ID for advertising and a unique device token.
- Location data, including data about the geographical location from your mobile device. On most mobile devices, you can control or deactivate the use of localisation services in a programme on your mobile device via the settings menu on your device. However, please note that Freemi’s services might not work as intended.
- Computer and connection data such as statistics about your use of our Services, your page views, your traffic to and from websites, referral URLs, posting data, your IP address, your browser history and your weblog data.
Personal data that we collect via cookies or similar technologies:
- If you would like more information about our use of these technologies and how they are controlled, please see the section Cookies and similar technologies below.
Personal data collected from other sources:
We are testing an IKEA partnership
Freemi and IKEA are co-operating to make it as easy as possible to recycle your old furniture and minimise waste. We are running campaigns together on social media in the spring of 2019 to get IKEA customers to download the Freemi application and start freecycling. Freemi will share aggregate level data about the customers who download the Freemi app through IKEA’s campaigns with IKEA Denmark and IKEA Netherlands. Freemi will also ask customers to participate in a short voluntary survey. The answers of the survey will be shared with IKEA but not the identities of the participants. IKEA will not share any personal data with Freemi, the co-operation is limited to promoting the Freemi application. If you wish to receive more information about the co-operation or how personal data is processed you can contact DPO and CTO, Jamie Neubert Pedersen at e-mail, email@example.com.
How we use your personal data
We use the personal data that we collect about you for a number of business purposes and based on a number of various processing bases. The following is an outline of how and on which processing bases we process your personal data. We use your personal data to enter into or execute agreements with you and to provide our services to you, to keep our legal obligation or protect your vital interests. This includes:
- Allowing you the possibility to access and use our services (in particular so that you can create, manage and interact with posts or other content), user account management, drive, assess, secure and improve our Services and adapt web content that includes elements and Services that you might want as a result of your actions.
- Giving you access to features that enable communication with other users.
- Contacting you regarding your user account, solving problems with your user account, settling a dispute or bad experiences or providing you with other forms of necessary customer service or support.
- When we contact you because of the above reasons, it may be via email, notifications or mobile push messages.
- Providing other services that you have requested as described when we collect the data.
- We use general information about geographical location to give you location-based Services (e.g. posts near you, search results and other customised content).
- Preventing, discovering, discouraging and investigating fraud, security breaches or other potentially prohibited or illegal activities.
We use personal data to pursue our legitimate interests if your interests, fundamental rights and freedoms do not take precedence over these interests. This includes processing occurring to:
- Improve our services, e.g. by processing data that make it possible to ensure accessibility, troubleshooting and the solution of problems that you have encountered in order to give you a better experience of our services.
- Adjust, assess and improve our advertising.
- Contact you via email, notifications and mobile push messages to offer you coupons, discounts, special offers and benefits, to hear your opinion via questionnaires or the like, to inform you of our Services or news that may be relevant to your use. This will always be in accordance with your preferences and current legislation, including the requirements in the Danish Marketing Practices Act (markedsføringsloven).
- Adjust our services, including our website, so that the content is better adapted to your preferences.
- Analyse the effect of our marketing campaigns (e.g. by analysing open and click rates).
- Monitor and improve the data security of our Services.
Based on your consent, we use your personal data to:
- Contact you with marketing via email, notifications and mobile push messages. This will always be in accordance with your marketing consent and the notification settings of your device.
- Adapt third-party banner ads including banner ads that show third-party websites in relation to your behaviour and your preferences.
- Use your geographical location to provide location-based services.
You may at all times withdraw your consent and change your notification and location settings on your device.
Your choices regarding the ways we use your personal data
You decide the methods we may use to contact you. Our Services ask you whether we may send you notifications and mobile push messages and whether you would like to have our newsletter sent to the email address with which you signed up.
If you no longer wish to receive marketing messages from us, you can unsubscribe via the link in an email you have received or turn off notifications and mobile push messages in your phone settings.
Freemi does not use your personal data for customised advertising programmes. If that turns out to some time be the case, we will ask for your consent. We do not allow third parties to track or collect your personal data on our websites for their own advertising purposes without your consent.
To stay logged in
When you log in on your user account with our mobile application, you will stay logged in. If you use a public or shared mobile device, we therefore recommend that you log out after use. You and any other user of the mobile device on which you are logged in will be able to see and gain access to most parts of your user account and to perform certain specific actions while you are logged in without further approval. The specific actions and user account activities that you or any other user of this mobile device may perform include:
- Create, report or inquire on posts
- Manage/delete your posts
- Manage/delete your free findings
- Send messages to other users
- Send feedback and support messages
- Request the closing of your user account
You can exit the session on which you are logged in by logging out and/or clearing your cookies. If you use a public or shared computer or mobile device, you should log off and/or clear your cookies when you are done using our Services to protect your user account and your personal data.
In that way, you can access, control and correct your personal data
Access to rectification and erasure of your personal data
- You can see, review and have most of your personal data changed by writing to DPO (Data Protection Officer) and acting CTO (Chief Technology Officer) Jamie Neubert Pedersen at firstname.lastname@example.org. You must update your personal data if they are changed or are incorrect.
- We will respect any legal right you may have to access, change or erase your personal data.
You may at all times and without further notice close down your user account by sending an email to email@example.com with the subject: “Closing of account”. We will close down your user account and remove all of your personal data so that they are no longer available. The erasure may take up to 30 days but in practice takes a shorter time.
How we may share your personal data
We may transfer your personal data to the following parties for the following purposes:
Service providers as follows:
- Third-party providers with whom we have entered into an agreement on assistance to provide our services, e.g. data processors and technical support. In these cases, the personal data will remain under our control.
Third-party providers of websites, programmes, services and tools as follows:
- Who are our partners in accordance with our Terms and Conditions so that they can publish or advertise your posts and their content on their websites or in their programmes, services and tools. If we transfer personal data together with the content of your posts to third-party providers, it will always be based on an agreement limiting third-party providers’ use of such personal data to the data processing that is necessary in order to perform their contract with us and that puts the third-party provider under an obligation to take security measures regarding such data. Third-party providers are not entitled to sell, lease or in any other way transfer the personal data included in your posts to third parties.
Other third parties as follows:
- Other third parties with whom you have given us permission to share your data via Freemi, e.g. within the framework of cooperation or a competition.
Enforcement of the law, lawsuits and as entitled to in accordance with current legislation as follows:
- To meet our obligations according to legislation, enforce our Terms and Conditions, react to complaints stating that a post or other content violates other persons’ rights or to protect other persons’ rights, ownership, IP rights or security.
- For legal or public authorities or authorised third-parties as a reaction to a verified request or lawsuit in connection with a criminal investigation or claimed or alleged, illegal activity or any other activity that subjects us, you or any other user to legal liability. We will only disclose data that we deem relevant to the investigation or examination.
- To finance companies or agencies in accordance with current national legislation.
- For third parties involved in a lawsuit if we are obliged to testify, if a court order exists or any similar legal basis or if we in any other way in good faith believe that revealing the data is necessary in order to avoid imminent danger of physical or financial loss or to report a suspicion of illegal activities.
Change of ownership as follows:
For how long do we store your personal data?
The period during which we store personal data may vary significantly depending on the context of the Services we provide and our legal obligations. The following factors typically influence our storage periods:
- For how long are the personal data necessary in order for us to provide our services? This includes matters such as maintaining and improving the efficiency of our Services, protecting our systems and storing relevant business and financial records.
- Are these personal data sensitive? In that case, a briefer storage period is usually used.
- Did you consent to a longer storage period? In that case, we will store data based on your consent.
- Are we subject to a legal, contractual or similar obligation to store your personal data? There might be e.g. laws governing data storage, orders from the authorities to store data that are relevant to an investigation or personal data that are stored due to a legal dispute.
When it is no longer necessary for us to store your personal data, we will dispose of them in a responsible manner in accordance with our processes for the storage and erasure of data.
Other important information about the protection of personal data
What happens when you share your personal data on our Services?
On our Services, the users may create posts and data with other users, thereby giving other users access to the shared data. As our application also makes it possible for you to contact a giver or user directly, we recommend that you consider how you share your personal data with others. You have the sole responsibility for personal data that you share with other users via our Services, and we can therefore not guarantee the protection or security of the data that you share with other users.
Your responsibility regarding data that you receive on Freemi
When you do a transaction with another user, we give you the possibility of acquiring or we may provide you with some of the user’s personal data (e.g. first name, user account ID, address) to complete the transaction. Independent of us, you are responsible for such data, and we recommend that you do not copy personal data and that you respect other users’ privacy. In any case, you must observe current legislation on privacy and allow the other user the change to be removed from your database.
You may only use the personal to which you have access for Freemi transaction-related purposes or for other services that are provided through Freemi (e.g. reports about fraud and communication between members) and for the purposes for which the user whom the data concern has given his or her express consent. Use of personal data about other users to which you have access for any purpose will constitute a violation of our Terms and Conditions.
Unsolicited or threatening emails
We do not tolerate any misuse of our Services. You are not allowed to add other users to your address list (email or mail), call a user or send a user text messages for commercial purposes. Sending commercial, unsolicited or threatening emails and text messages violates our Terms and Conditions. If you would like to report Freemi-related spam, attempts of commercial contact or fake emails, please notify us at firstname.lastname@example.org.
Our websites are intended for a wide audience but are not intended for children. You must be at least 18 years old to create a user account on our Services. We do not knowingly collect personal data from users that are considered minors in accordance with their respective, national legislations.
Third-party practice regarding the protection of personal data
We cannot guarantee the protection of your personal data when you give them to a third party, and we recommend that you evaluate your business partner’s privacy and security policies before you enter into a transaction and choose to share your personal data. This also applies if the third parties to whom you give personal data are offerors, buyers or sellers on our Services.