Last Updated: March 3, 2019

Thank you for choosing to be part of our community at Freebs Inc, doing business as Freebs (“Freebs”, “Us”, “The Company”, “We” or “Our”). Our goal is to connect people who believe in fully utilizing everyday items of value. Because we are a technology company, we will collect data to provide services to you and also to improve how we deliver those services to you. Dealing with data can be complicated, however, we would like to assure you that we will respect and take the protection of your data, and your privacy seriously. If you have any questions regarding our privacy policy or practices with regards to your personal information, please contact us at support@freebs.io.

In this Privacy Policy, we seek to explain in the best possible way, what information we collect, how we use it and what rights you have in relation to the information we collect about you when you access our website, applications (“Sites” and “Apps”) and services (includes but not limited to sales, marketing and events). If you are a user in the European Union, please make sure to take a look at our Data Rights and European Union User Consent clause. 

This Privacy Policy covers your use of our Sites (including subdomains) and Apps. It also covers your use, access or utilization of our services as well as any of your interactions with us.

Any information that we collect is subject to our Privacy Policy and this Policy is in effect at the time such information is collected.

From time to time we may modify this Policy. We reserve the right to do so and when we do make modifications, we will notify all registered users through email, our Sites or our Apps about the existence of the new Policy. If you continue using our Sites, Apps and Services after the changes to the Policy are effective, this constitutes your acceptance of and agreement to be bound by the new Policy.

At any time, you can access the current Policy in the Privacy Policy section under the F.A.Q section of our Apps or at the bottom(footer) of our Sites. You can also request this Privacy Policy by emailing us at support@freebs.io with the subject "Privacy Policy Copy". 

Freebs Inc. understands ‘consent’ to mean that it has been explicitly and freely given, and as a specific, informed and unambiguous indication by statement or by a clear affirmative action through use of our platforms and services, that you the user are in agreement to the collection and processing of personal data relating to you the user by us the Company. We understand ‘consent’ to mean that you the user have been fully informed of the intended processing and collection of your data and have signified your agreement, while in a fit state of mind and do so without pressure being exerted upon you by us or any other source. We understand that consent obtained under duress or on the basis of misleading information will not be a valid basis for processing your personal information. You the user can withdraw your consent at any time and in addition if at any time you feel that your consent has been misused or our terms of consent are not clear please email us at support@freebs.io with the subject "Consent" or contact us within our Sites and Apps using the Contact Us feature.

Content is anything you upload to our Sites, Apps or Services. This includes location data, your user data, images and text you enter. We will not upload content on your behalf unless where technical issues arise, and you have given explicit written consent either by email or by contacting us through our Sites, Apps or Services. Should you choose to share your uploaded content, we may upload your content automatically to third-party services such as Facebook, Twitter, and Google only after you the user triggers our sharing functions within our Sites, Apps, and Services.

We may aggregate and anonymize information for a wide range of business, security, performance, and analytical purposes. The aggregation and anonymization process prevents the information from being re-associated or identified with any one customer account, user or individual. Upon activation of account deletion, request for amendment or activation of the "16. Data Rights and European Union User Consent - Right to be Forgotten" clause, some of the information already aggregated may not be deleted or erased. The reason being that the data may not be re-associated or identified with any one customer account as previously mentioned.

In our Sites, Apps, and Services, we collect some specifically identifiable personal information including:

• Full Name
• Personal Email
• Date of Birth
• Profile Images

We use your Full Name and Personal Email to create and administer your account. We also use your Personal Email to contact you or send you suggested services, events we may be working on as well as marketing material. We use your Date of Birth to verify that you are above thirteen (13) years of age which is our age requirement for you to be able to use our Sites, Apps, and Services or that you are between thirteen (13) and eighteen (18) years of age and have obtained parental or guardian consent. We use your Profile Image to allow other users to identify you and or your account when they interact with you. We may use the personally identifiable information both provided by you the user or other information collected by us about you from other sources for the reasons listed in 10. "How Do We Use the Information We Collect?" only to the extent necessary for the purposes for which you have given permission as well as for the following non-negotiable purposes:

• To act consistently with our terms of use
• To respond to Law Enforcement or other governmental or legal authorities within Freebs Inc headquarters location or in the jurisdiction where you the user utilize our services
• To use the information consistent with your instructions to us such as when you contact us directly with a request or when you engage us to provide you services

The information we collect from you depends on your use of our Sites, Apps and Services. Below is an indication of when (time of) we collect your information and what information we collect at the time of collection. We collect your information when:

• You create an account with us using email
• You create an account with us using 3rd party services (e.g. Google and Facebook)
• You enter the images, descriptions, and locations of the items you post. We share this information with other users. Some of the information may be accessible to non-registered users in whole or in part such as when posts are shown pre-login as a way to show potential users what content and services they can expect by using our Sites, Apps and Services. Such posts may contain your name, description of the posted item and its location you enter. All the information on the posts you make live is available in whole to registered users
• You authorize us to access your location data in the settings menu of your device or if you volunteer your location information by selecting your default location in our Site or App. When you share your location data, we may obtain your location information from your internet/network service provider
• You post ratings and feedback of other users that have successfully grabbed posted items from you
• Other users post ratings and feedback about you when you grab other users' listed items
• You post. Particularly, time, date, location, file sizes among other data attributes or the posts
• You grab things on our platform. We may collect date grabbed, location when grabbed, session duration among other data attributes
• You post in the questions section of the individual posts. These questions are public and visible to all registered users that interact with the post in question
• You send messages to other users. These messages are only visible to you and the corresponding user through the messages feature. Only when necessary such as in the event of a dispute between users or request from law enforcement or governmental obligation depending on the jurisdiction, an authorized Freebs Administrator may access the messages to resolve the situation
• You contact us through the Contact Us feature in our Sites and Apps
• You contact us through other means other than our Sites and Services, we may collect your email and the contents of your message
• You generally use our Sites, Apps, and Services. We collect your usage activity without you having to post or grab anything. We use the information for determining usage patterns of users on our platform, so we can better improve our services. Some of the information we may collect include duration of Sites, Apps or Service use, location, posts interacted with, file sizes, categories of posted items and favorited posts among other data attributes

We collect information about how you use our services and your actions on the services we provide. This is done by tracking and storing data of your interactions with the features available our Sites, Apps and Services. We may collect this information automatically. We also may collect this information if you are not a user but interact with our Sites, Apps and Services.

At times we may employ cookies or similar technology such as web beacons to automatically collect this information. This information may not directly reveal your identity but may include

• Your device type
• Your IP address
• Your browser and device characteristics such as settings
• We may collect data on the hardware you use (phone type, computer type)
• We may collect data on the operating system version of your hardware
• We may collect information on the network service provider you use
• We may collect data on your general Sites, Apps and Service usage patterns such as interactions with posts, views on posts, clicks on profiles and other data generating activities

We use this information to understand our user’s preferences, so we can improve our service delivery as well as to maintain the security and operations of our Site, Apps, and Services.

We use the information we collect about you for a variety of purposes. How we use the information depends on what services you use and the information we collect. We may use the information for the following purposes:

• Providing customer support and technical assistance
• Contacting you to provide product updates or information about products you have requested or purchased
• Marketing Freeb's products, services, and events
• Monitoring the performance and security of our platform
• Creating and administering your account
• Identifying you with your account for various reasons including marketing, technical support, and legal reasons
• Deriving market insights, ways to improve our service and other business analysis and research activities
• Customizing existing product offerings, creating new product offerings
• For security reasons, that is to secure and protect your information and data
• Sharing with 3rd parties as discussed in ”12. How Do We Share Information?" and in "14. Location Information" sections
• Delivering targeted advertising to you
• Administer prize draws and competitions
• Request feedback
• Enabling communication between us and our users as well as between our users
• Any legitimate business purpose, internally and with business partners (for business partners: provided that the information is aggregated and anonymized)
• For providing the service to you; where you (or, if you are an end user, the Freebs user through which you have an account) explicitly approve access (e.g., during a customer support inquiry)
• Where compelled to do so in response to lawful requests by law enforcement or government regulators
• Where necessary to ensure the stability and security of the services and our systems (e.g. where we have reason to believe specific content is degrading server stability)
• Where necessary to protect the rights, privacy, safety, or property of you, us, or others
• Analysis of metadata related to content (such as total number of records, file size, API volume, access logs, etc.) to improve the performance of our systems and for security purposes

The content you upload is viewable in whole or in part by other users; both registered and non-registered. You the user controls the nature of the content. Freebs will enforce content guidelines as detailed in accordance with our Privacy Policy, Terms of Use and within legal guidelines. Please note that our collection, use and disclosure practices for the content you upload are separate from those of the information we collect about you such as personally identifiable information.

For the content, you upload, we also reserve the right to prohibit, delete or report to the appropriate authorities, the posts you make including the content you upload if they (posts and or content) are not in line with our usage policies or legal and governmental requirements of your jurisdiction at the time of  posting or at the time that you utilize our services.

We may disclose your information including the content you create under the following conditions:

• You provided information to us through posted items. Information such as location, owner and description of items will be shown to registered and non-registered users in the form of posts
• You gave explicit consent by posting items on our Sites, Apps and Services
• With advertisers for them to show you appropriate and relevant advertisements on our Sites, Apps and Services. Please note we do not share your personally identifiable information with advertising partners
• With 3rd party services to which you already have an account with such as Facebook, Google+ or Twitter in order to share your postings or content you create. In such cases, personal information such as your name and location of the items posted may be visible to non-registered users. Please note sharing posts is a user triggered function. We will not automatically push your posts to 3rd party platforms even to ones to which you already have accounts unless you trigger the functionality
• When we advertise our services on other platforms, we may use existing content generated by you the user. This information may contain your name as it appears on the posts you make, the location of the posted items, description of the posted items and any associated images of the posted items. An example of such use would be an advertisement about the Freebs app on the Facebook platform.
• With 3rd party services providers (Vendors, Consultants, and Other Third-Party Service) who enable certain features of functionalities that our Sites, Apps and Services rely on in order to provide you with services. For example, Google+ and Facebook, which are used to login and account creation or other key business partners that enable email delivery, hosting services, marketing, user tracking, payment processing (for business users buying ad space) or data analysis
• With business partners for any legitimate business purpose
• As necessary in the event of a proposed or actual reorganization, merger, sale, joint venture, business model pivot, assignment transfer, financing or other dispositions for all or any portion of Freebs business assets and or stock. In such cases, typical agreements request access in whole or in part to non-aggregated Freebs data, intellectual property, and systems. As such, user data may be accessed in whole or in part by the parties involved under strict non-user compromising guidelines
• With your consent, for any other legal purposes and for any other purposes that are also in line with our Terms of Use

We use Google Maps through our Google Maps API Implementation and in accordance with Google’s Privacy Policy. To view Google Maps APIs Terms of Service and Google’s Privacy Policy, you can refer to the links below:

• Google Maps API:  https://cloud.google.com/maps-platform/terms/
• Google's Privacy Policy:  https://policies.google.com/privacy

By using our Google Maps API Implementation, you agree to allow us to gain access to personally, identifiable information (usernames and profile information) and non- personally identifiable information such as location and location history which we use to help us suggest appropriate content as well as to assist you the user to quickly list the general location of the items you post. We may use the Google Maps data in conjunction with data from other sources in order to provide such services. For more information on what we use your personal information for, please see additional details in the section: “10. How Do We Use the Information We Collect?”  and in the section “12. How Do We Share Your Information?”

We may collect information on your location in several ways other than through our Google Maps API Implementation. For example, we may use the location you enter on your posts to indicate where the particular items you posted are generally located. The information may be shared with other users, both registered and non-registered. We may also use this information for general usage statistics. We may also use your IP addresses and convert it into a rough geolocation to understand in what areas our users are located in order to help improve our services. Also, because our services are in part supported by advertisements, we in some cases may use location information to help show the appropriate advertisements as we work with our advertising partners.

Freebs’ Sites, Apps and Services allow you the user to register using third-party social media and email accounts such as Facebook and Google. If do choose to create your Freebs account using third-party accounts that we support, we will receive certain personally identifiable information and non-personally identifiable information. Such information varies based on the third party used however at a minimum we receive:

• Your full name
• Email addresses
• Profile picture

If there is other information you chose to make public with your third party social media or email account, we may receive that as well.

All information received will be used in accordance with our Privacy Policy however since we do not control or maintain any of your third-party accounts, we are not responsible for other uses of your personal information by your third party social media or email account provider. Please review their privacy policies to understand how they collect and share your personal information so you can set your preferences.

If you are a user in certain jurisdictions such as the European Union, you may have certain rights under applicable data protection laws.

Below are your rights pertaining to your personal information and the data we collect about you. To actively exercise any of those rights please feel free to email us at support@freebs.io with the subject being the right/clause you would like to exercise for faster processing.

If you are a resident of the European Union and believe we are unlawfully processing your personal information, you may file a complaint with your local data protection supervisory authority which can be found here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

To exercise your rights, you can either:

• Log into your account and navigate to your profile where you can access settings and update your user account
• You also have the option to contact us in regard to the rights below as well as general questions about our Privacy Policy art support@freebs.io.

Below are your rights pertaining to your personal information and the we collect about you:

(a) Right to be informed about:

• The identity and the contract details of any company including Freebs Inc collecting data about you on our platforms
• The purposes of collecting your data and processing of the data
• The purposes and intentions pursued by Freebs Inc in-regards to your data
• The right to know the period for which your personal data will be stored
• The existence of and logic behind automated decision-making based on your data and its consequences

(b) Right of Access:

• You have the right to access or request the purposes of our data processing using your data
• You have the right to access categories of your personal data collected
• You have the right to know the recipients or to whom your personal data will be disclosed
• You have the right to know the period or length of time your information will be stored

(c) Right of Rectification

You have the right to rectify and amend inaccurate personal data concerning yourself. You can do this by logging in to your Freebs account and navigating to your profile. You can also email us with your request at support@freebs.io with the subject Personal Data Rectification.

(d) Right to be Forgotten/ Right to Erasure

You have the right to request that we erase all your personal data without undue delay. Please note however that aggregated and anonymized data may not be subsequently deleted. As stated in the "Aggregated and Anonymized Data" section, the aggregation and anonymization process prevents the information from being re-associated or identified with any one customer account, user or individual. Delete-able data will be that which can directly identify you or your profile.

If you request to terminate your account for general purposes or in-order to trigger the Right to be Forgotten/Right to Erasure clause we will deactivate and delete your account data from our databases. However, in addition to aggregated non-personally identifiable information, we may retain some information in our files to prevent fraud, resolve ongoing disputes (between users), troubleshoot problems, assist in investigations by law enforcement or to comply with legal requirements as we all for compliance with our Terms of Use.

(e) Right to Restrict Data Processing

You have the right to restrict or request that we stop processing your personal information if you contest the accuracy of your personal information. You can inform us by emailing us your request at support@freebs.io with the subject "Restrict Data Processing". In addition, we have period data audits to delete any of your personal information we no longer need to provide you with our services.

(f) Right to Data Portability

You have the right to request your personal data that you have provided to Freebs. We will provide you the personal data in structured, commonly used and machine-readable format. To request your personal data please email us at support@freebs.io with the subject "Personal Data Porting Request".

(g) Right to Object:

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Freebs features, products, events or other opportunities from our partners. You have the right to object to the processing of your personal data for such purposes. You can object by unsubscribing to those requests. However, our Sites, Apps and Services are currently supported by advertisements. These advertisements do no use personally identifiable information. They use general usage patterns derived from posts made and accessed as a result the advertisement shown on our platforms are general marketing and may not be unsubscribe-able.

(h) Right to Human Decision:

You have the right to not be subject to automated decisions based solely on our automated decision processes and systems, especially when such automated decision making significantly and negatively affects you the user. If you feel that this right has been violated, please free to notify us by email at support@freebs.io with the subject "Right to Human Decision".

We process and store information on servers located in the United States, and we may store information on servers and equipment in other countries depending on a variety of factors that include the service availability and fail-safe procedures of our hosting service providers. We review our hosting service providers’ policies to ensure they meet our privacy guidelines. By using our Sites, Apps, and Services, you consent to the transfer of your information (including personally identifiable information) to locations that may be outside of your country of residence or jurisdiction where you are accessing our Sites, Apps, and Services from.

By using our services while in the European Union, you acknowledge and agree that as a condition for us to provide you with such services or for you to access our Sites and Apps that we can transfer your personally identifiable information, as well as the content you create to the United States or another country where our hosting service provider may host our Sites, Apps, and Services. 

If you are a user domiciled in the State of California, due to the “Shine the Light Law” – California Civil Code Section 1798.83, you are permitted to:

• Request from us once annually, information about categories of your personal information that we shared or disclosed to third parties (if we collected any personal information) for direct marketing purposes
• The names and address of all third parties with which we shared personal information within the immediately preceding calendar year
• Request to the removal of unwanted data that is posted on our Sites, Apps, and Services if you are under the age of eighteen (18). To request this, please contact us at the email address below with proof of your California Residency. We will try to remove all the data you request however please be aware that data may not be completely or comprehensively removed from our systems or the internet in general (due to other non- associated archiving and data aggregation services used by third parties not affiliated with us).

To these requests, please email us at support@freebs.io.

If you have any questions or concerns about our Privacy Policy, you may contact our Data Protection Officer (DPO) at mahachi@freebs.io with Email Subject Attn: Data Protection Officer.