This privacy policy notice is for this website; www.freedomhotspot.com and served by Freedom Hotspot (trading name for Multinet Services Ltd; Company Reg: 3241812) with a trading address of Boston House, 69-75 Boston Manor Road, Brentford, Middx, TW8 9JJ and governs the privacy of those who use it.

The Policy

The purpose of this policy is to explain to you how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations. If you do not agree to the following policy, you may wish to cease viewing / using this website.

Policy key definitions:
  • “I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
  • “you”, “the user” refer to the person(s) using this website.
  • GDPR means General Data Protection Act.
  • PECR means Privacy & Electronic Communications Regulation.
  • ICO means Information Commissioner’s Office.
  • Cookies mean small files stored on a user’s computer or device.
Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

  • To prevent fraud.
  • To detect, prevent and diagnose potential security breaches.
Legal basis for the collection and processing

We are registered with the ICO under the Data Protection Register, our registration number is: ZA046288.

Data protection law sets out the conditions under which personal data can be collected and which we use as the basis for collection and processing, these include:

Contractual obligations

When you purchase a service, we need to collect personal data to fulfil our legal contractual obligation, for example: so, we can manage and invoice your account and contact you for technical support purposes.

Legal compliance

The law requires we collect and process data for certain purposes such as for keeping financial records (i.e. invoicing) and that we can comply with law enforcement requests for data.

Legitimate interest

We collect data under legitimate interest in a way that is reasonably expected as part of the day to day running of our business.

For example, we collect and log IP addresses for fraud protection and security as well as analysis of our site usage.

Consent

In certain cases, we may collect and process your data with your consent, for example our newsletter and hot offers emails. Consent to receive these can be withdrawn at any time.

When do we collect your personal data?
We may collect data about you in the following ways:
  • By filling in forms on any of our websites, this includes information provided at the time of registering to use our websites, subscribing to any of our services, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us or if you report a problem with our site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of transactions you carry out through our site and of the fulfilment of your orders.
  • Visiting our sites, including, but not limited to, traffic data, location data and other communication data required for our own security, diagnostic, authentication and billing.
Your individual rights

Under the GDPR your rights are as follows. You can read more about your rights in details here;

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR.

Internet cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third-party website.

Some cookies are required to enjoy and use the full functionality of this website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Cookies that we use are for Google Analytics, which are used for improving the performance/usability of the website and to track visitors to it.

Data security and protection

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

Transparent Privacy Explanations

We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an Email Marketing Service (EMS). An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preference or alternatively contact the EMS service provider.

Our EMS provider is; MPZMail & Sendgrid but may change. We hold the following information about you within our EMS system;

  • Email address
  • I.P address
  • Subscription time & date
  • Date and time emails sent

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