Privacy Policy

1.1 Important information and who we are

Welcome to Freak Holdings Ltd's Privacy and Data Protection Policy ("Privacy Policy").

At Freak Holdings Ltd ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Business contacts

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Freak Holdings Ltd is your Data Controller and responsible for your Personal Data.

We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Any inquiries about your data should be sent to general@freakout.ai or by post to 11 John Street, Kingswood, Bristol, BS15 8BT, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors' responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR.
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data.
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor.
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights.
• Make available to the Controller all information necessary to demonstrate compliance with GDPR obligations and allow for and contribute to audits, including inspections.
• Maintain a record of all categories of processing activities carried out on behalf of a Controller.
• Cooperate, on request, with the supervisory authority in the performance of its tasks.
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller.
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2.1 Types of data / Privacy policy scope

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: first name, last name, gender, and date of birth.
• Billing Data: debit and credit card information, the name attached to your payment details, and your billing address.
• Financial Data: banking details such as your account number and sort code.
• Transactional Data: details and records of all payments you have made for our services or products.
• Technical Data: IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: feedback and survey responses.
• Usage Data: information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as usage trends across different user segments to help us personalize the product experience, improve performance, and make informed decisions about future product development.

Aggregated Data does not directly or indirectly reveal a user's identity. If we combine or connect Aggregated Data with your Personal Data so that it can identify you, we treat the combined data as Personal Data used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this anonymous data with others, including service providers, affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you, including details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic data or biometric data. Nor do we collect information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• Consent: Certain situations allow us to collect your Personal Data, such as when you opt in to a service.
• Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• Legal Compliance: We are required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• Legitimate Interest: We might need to collect certain information from you to meet our legitimate interests as part of running our business, where this will not have a material impact on your rights, freedom or interests.

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Examples are indicative, and the purposes for which we use your data may be broader than described, but we will never process your data without a legal basis for doing so and for a related purpose.

3.2 Marketing and content updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may process your Personal Data without your knowledge or consent where this is required or permitted by law.

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with.
• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Right to rectification. You have a right to request correction of incomplete or inaccurate personal data that we hold about you.
• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, subject to legal exceptions.

• Right to object. You can object to processing of personal data we hold about you, including where we process data for direct marketing or rely on legitimate interests and your situation gives you grounds to object.
• Right to restrict processing. You can request restriction or suppression of personal data in certain circumstances, including while accuracy is established, where use is unlawful but you do not want erasure, where you need us to hold data for legal claims, or while we verify overriding legitimate grounds.
• Right to data portability. You can request transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format where the right applies.

If you wish to make a request under any of these rights, please contact us at general@freakout.ai.

4.2 Your control over Freak Holdings Ltd's use of your Personal Data

You may delete your account at any time. This will remove your account page from our systems and related software. You can access information associated with your account by logging into your account.

Your account information will be protected by a password. You need to prevent unauthorized access by selecting and protecting your password appropriately, limiting access to your computer or device, and signing off after you have finished accessing your account.

California residents may ask us for a notice identifying the categories of personal customer information which we share with affiliates and third parties for marketing purposes. Requests may be sent to general@freakout.ai.

4.3 How Freak Holdings Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement security measures including encryption, ssl, and jwt. Personal Data is accessible only by a limited number of employees with special access rights who are bound by confidentiality obligations.

If we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. No internet transmission is guaranteed to be completely secure, and any transmission is done at your own risk. If you believe your interaction with us is no longer secure, please contact us.

4.4 Opting out of marketing communications

You can ask us to stop sending marketing messages at any time by following the opt-out instructions in those communications. Where you opt out, we will continue to retain other Personal Data provided to us as a result of interactions not related to your marketing preferences.

4.5 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data or exercise your other rights. If your request is clearly unfounded, we could refuse to comply with it.

We may need to request specific information to confirm your identity and ensure you have the right to access Personal Data or exercise your other rights. We may also contact you for further information in relation to your request to speed up our response.

5.1 Sharing your data with third parties

We may share Personal Data with interested parties if Freak Holdings Ltd anticipates a change in control, acquisition of all or part of our business or assets, or in connection with licensing our technology.

If Freak Holdings Ltd is sold or makes a sale or transfer, we may transfer, sell or assign your Personal Data to a third party as part of that transaction. In other situations, your data will remain protected in accordance with this Privacy Policy as amended from time to time.

We may share your Personal Data at any time if required for legal reasons or to enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.