Last modified:October 13th, 2025

 

 

Introduction

 

 

Freely Payments Inc. (“Freely”, “we”, “our” or “us”) develops and operates fintech platform, which includes Freely app, Freely Accept and Freely Pay (together – “Platform”). We also operate the website https://freelypayments.com/, its subdomains and its related features (“Website”, and together with the Platform – the “Services”).

 

 

Freely is dedicated to protecting your privacy rights and making our practices regarding your Personal Information transparent and fair. This Privacy Policy (“Policy”) is designed to help you understand how we collect, store, use and share your Personal Information. This Policy applies whenever you visit our Website, install any app or software, interact with our Platform, or otherwise access or use any of our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

 

 

Specifically, this Policy describes ––

 

 

1.        What types of information we collect?

2.        Tracking Technologies

3.        Why we process your Personal information?

4.        With whom we share your information?

5.        Your rights

6.        Transfer of Personal information

7.        How we protect your information?

8.        Minors

9.        Retention

10.        Updates to this Policy

11.        Controlling version

12.        Data Protection Officer

13.        Contact us

 

 

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy, at any time.

 

 

You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the full range or with the best experience of using our Services

 

 

 

 

1. What types of information we collect?

 

 

We collect personal information about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively "Personal Information"). This section sets out how and when we collect and process Personal Information about you.

 

 

   1. Account Information. When you register to our Services or otherwise use our Services, we collect your full name, nickname, password, email address, phone number and your company's name. If you choose to log in, access or otherwise connect to the Services through an external service (such as Google, etc.), we may collect your user ID and/or username associated with that external service, as well as any information you make public using that external service or that the external service allows us to access.

 

 

   2. Communication Information. When you send us an email or contact us via the support in our Platform or Website, we collect the Personal Information you provide us. This may include your name, email address, phone number, your company name and any other information you choose to provide.

 

 

   3. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include IP address, unique identifiers (e.g., MAC address and UUID), as well as other information which relates to your activity in the Services.

 

 

   4. Device Information. We may collect Personal Information from your device, such as non-precise geolocation information, IP address and other online identifiers (i.e. online data collected from individual's devices, applications and protocols which leave traces which may be used to identify individuals).

 

 

   5. Voluntary Information. Voluntary information provided by as part of your use of the Services or otherwise collected from time to time (for example, through surveys) to enable us to improve our Services or consider the wider needs of our users or potential users, or voluntary information that might be collected from you upon request and subject to your specific consent, for the purpose of provision of any of the Services to you. We also collect your communication or information provided by you to us when you respond to communications from us, provide us with feedback, communicate with us via email or other digital medium or share additional information about yourself through your use of the Service, including submission of any form or request via Services.

 

 

   6. Communication Information. When you send us an email or contact us via the support in our Platform or Website, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.

 

 

2. Tracking Technologies

 

 

Cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies") may be used by third parties (for example, our business partners), who run content on our Services – these are called "Third Party Tracking Technologies", and they allow to automatically collect information about you. Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

 

 

There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include: changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features may not work properly or effectively if you delete or disable cookies. 

 

 

 

 

3. Why we process your Personal information?

 

 

This section explains for what purposes we use your Personal Information:

 

 

1. Provision of our Services; support: We use your Personal Information, such as, but not limited to, your name, nickname, password, phone number, and email address, for consumer services purposes (including  merchant processing receipts); to provide and operate the Services (including, without limitation, responding to your inquiries and authenticating your access to the Services); and to communicate with you and to keep you informed of our latest updates to our Services. Moreover, we use your Personal Information for customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries. We also use your Personal Information to provide you with support, materials and information. The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).

2. Improve our Services: We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services.

3. Integrity: We may process certain information about you and your use usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.

4. Compliance with applicable laws: We process your Personal Information in order to comply with our legal obligation under applicable laws.

5. Business transactions: We may process and share your Personal Information in the event of a business transaction (e.g. merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets) in relation to the Company.

6. Dispute resolution and protection of our legal claims: We collect your Personal Information in order to investigate violation of our policies, enable us to resolve disputes in connection with your use of the Services and to establish and defend our legal claims.

 

 

 

 

 

 

 

 

4. With whom we share your information?

 

 

We may share, sell and disclose your Personal Information as described below:

 

 

1. Affiliated companies: We may share Personal Information internally within our affiliated companies and subsidiaries, for the purposes described in this Policy. 

 

 

2. Payment processors: We share your Personal Information with third party payment processors, for the purpose of facilitating your payments when using our Services (e.g., Payroc). These third parties may have access to your Personal Information so that they may perform these tasks.

 

 

3. Service providers: Our service providers work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the services and cloud storage vendors.

 

 

4. Compliance with laws and law enforcement entities: We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

 

 

5. Auditors and advisers: We may share your information with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.

 

 

6. Mergers and acquisitions:  We will transfer, sell or otherwise share your information with potential purchasers, successors or investors, in case of entering into a business transaction such as merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

 

 

These recipients may only use Personal Information on our behalf or for specific permissible purposes, and are subject to strict confidentiality and data protection requirements as part of our contractual arrangements with them, while ensuring compliance with all applicable data protection regulations. When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services.

 

 

In the 12 preceding months, we have collected and/or disclosed the following categories of Personal Information:

 

 

Category of Personal Information Collected

 

 

Service providers

 

 

Service providers

 

 

 

 

 

Sources of Personal Information

 

 

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

* Directly, through your activity on our Services: For example, from your interaction with the Website and our Platform.

* Indirectly from you:  we track your activities across the internet, for example, when you view or interact with certain content, web page or ad.

* From third parties: For example, from vendors who assist us in providing the Services or external services through which you connect (e.g., Payroc, Google, as applicable).

 

 

We do not offer financial incentive to end users for providing Personal Information.

 

 

We do not “Sell” or “Share” Personal Information about you, as these terms are defined under US Privacy Laws. 

 

 

 

 

5. Your rights

 

 

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

 

 

   7. Rights of access to your Personal Information:

The right to receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information.

 

 

   8. Right of data portability: 

The right to request us to move, copy and transfer your Personal Information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

 

 

   9. Right of rectification: 

The right to request rectification of your Personal Information in our control in the event that you believe the Personal Information held by Freely is inaccurate, incomplete or outdated.

 

 

   10. Right of deletion/erasure: 

The right to request that Freely erases or deletes Personal Information held about you at any time.

 

 

   11. Right to restriction or objection to processing: 

The right to request that Freely restricts or ceases to conduct certain Personal Information processes at any time.

 

 

   12. Right to withdraw your consent: 

To the extent we process Personal Information on the basis of your consent, you have the right to withdraw your given consent at any time.

 

 

   13. Right to limit use and disclosure of your sensitive Personal Information: 

The right to request to limit the collection of your sensitive Personal Information, to that use which is necessary to perform our Services.

 

 

   14. Right not to be subject to automated decision making:

The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

 

 

   15. Right to opt-out of the sale or share of Personal Information: 

In the event that we sell or share your Personal Information for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Information. After you opt-out, we may continue disclosing some Personal Information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

 

 

   16. Right to non-discrimination: 

The right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. 

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.

 

 

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

 

 

Authorized agent

 

 

1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

   1. The authorized agent is a natural person or a business entity; and

   2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

 

 

2. The request must:

   1. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you; and

   2. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

 

 

3. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

 

 

4. Making a verifiable consumer request does not require you to create an account with us. 

 

 

 

 

6. How do we protect your information?

 

 

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Information you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

 

 

7. Minors 

 

 

Our Services are only eligible to individuals who are the greater of eighteen (18) years of age or the age of legal majority in the applicable jurisdiction ("Applicable Age"). We do not knowingly collect or solicit Personal Information from anyone under the Applicable Age. By accessing, using or interacting with our Services, you certify to us that you are not under the Applicable Age. In the event that we learn that we have collected Personal Information from an individual under the Applicable Age without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Applicable Age, then please contact us through the contact details available below.

 

 

8. Retention 

 

 

We will retain your Personal Information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

 

 

 

 

9. Updates to this Policy 

 

 

We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

 

 

10. Controlling Version

 

 

The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the meaning of the English language version shall prevail.

 

 

11. Data Protection Officer

 

 

The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. If you have any questions about this Policy, please contact our Data Protection Officer (the contact details are available in the "Contact Us" section). 

 

 

12. Contact Us

 

 

If you have questions about this Policy or our privacy practices, please contact us:

Freely Payments, Inc.

Attn: Privacy Team

1775 Tyson’s Boulevard

McLean, VA 22102

Email: privacy@freelypayments.com