Privacy Policy

This website is operated by Freefort Limited t/a Freefort. Freefort is a company registered in England and Wales under company registration number 08505142 and our registered office address is The Courtyard Shoreham Road, Upper Beeding, Steyning, West Sussex, United Kingdom, BN44 3TN. Throughout this Privacy Policy, references to “we”, “us” and “our” are references to Freefort Limited. This privacy policy sets out how we use and protect your personal data.

We are a “data controller” for the purposes of the applicable data protection laws, including the Data Protection Act 2018 and the UK General Data Protection Regulation (“Data Protection Legislation”). This means that we are responsible for the way in which your personal data is collected and processed, and we have a legal duty to comply with the applicable Data Protection Legislation.

Our data protection registration number is: ICO:00041452045.

We are committed to safeguarding the privacy of our website visitors and we ask that you read this privacy policy carefully as it contains important information on how we collect and use your personal data in accordance with our legal obligations.

This website is not intended for children and we do not knowingly collect data relating to children.

(1) What information do we collect?

Personal data means any information about an individual from which that person can be identified. We may collect, store and use the following kinds of personal data:
a) Identity Data including first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
b) Contact Data including billing address, delivery address, email address and telephone numbers.
c) Financial Data including bank account and payment card details.
d) Transaction Data including details about payments to and from you and other details of products and services you have purchased from us.
e) Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
f) Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
g) Usage Data including information about how you interact with and use our website, products and services.
h) Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.

(2) How is your personal data collected?

We use different methods to collect data from and about you including through:
a) information that you provide to us when contacting us by post, phone, email or otherwise;
b) information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters; and
c) any other information that you choose to send directly to us.

(3) Cookies

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.

(4) Using your personal data

Personal data submitted to us via this website will be used for the purposes specified in this privacy policy or in relevant parts of the website.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
a) Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
b) Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
c) Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
d) Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We may use your personal data to:
a) if applicable, send statements and invoices to you, and collect payments from you;
b) send you general (non-marketing) commercial communications;
c) send you email notifications which you have specifically requested;
d) (send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications). If you opt out of marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes;
e) deal with enquiries and complaints made by or about you relating to the website.

We will not without your express consent provide your personal data to any third parties for the purpose of direct marketing.

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes (including satisfying any legal, regulatory, tax, accounting or reporting requirements). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

(5) Disclosures

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy.

In addition, we may disclose your personal data:

a) to the extent that we are required to do so by law;
b) in connection with any legal proceedings or prospective legal proceedings;
c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling; and
e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Except as provided in this privacy policy, we will not provide your information to third parties.

(6) International data transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy policy. Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it. We shall not transfer your personal data to countries which do not have data protection laws equivalent to those in force in the UK without your express written consent.

(7) Security of your personal data

We will take reasonable technical and organisational precautions to prevent the accidental loss, misuse, access or alteration of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

(8) Policy amendments

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

(9) Your rights

You may instruct us to provide you with any personal data we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We may withhold such personal data to the extent permitted by law.

You may instruct us not to process your personal data for marketing purposes by email at any time. In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.

You may request a correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

In some circumstances you have the right to the erasure of your personal data without undue delay.

Those circumstances include:
a) the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) you withdraw consent to consent-based processing;
c) you object to the processing under certain rules of applicable data protection law.

However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

In some circumstances you have the right to restrict the processing of your personal data.

Those circumstances are:
a) you contest the accuracy of the personal data;
b) processing is unlawful but you oppose erasure;
c) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and
d) you have objected to processing where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data and we cannot demonstrate legitimate grounds to process your information.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it:
a) with your consent;
b) for the establishment, exercise or defence of legal claims;
c) for the protection of the rights of another natural or legal person; or
d) for reasons of important public interest.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

(10) Third party websites

The website may contain links to other websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the privacy policies or practices of third party websites. When you leave our website, we encourage you to read the privacy policy of every website you visit.

(11) Updating information

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Please let us know if the personal data which we hold about you needs to be corrected or updated.

(12) Contact

If you have any questions about this privacy policy or our treatment of your personal data, please write to us by post to Freefort Ltd, The Courtyard Shoreham Road, Upper Beeding, Steyning, West Sussex, United Kingdom, BN44 3TN