Effective 10th May 2018

Updated:

• 28 Dec 2019 - added CCPA section
• 10 Jun 2024 - Pursuant to the EU-U.S. DPF, the EU-U.S. Privacy Shield Framework Principles have been amended as the “EU-U.S. Data Privacy Framework Principles”; and pursuant to the Swiss-U.S. DPF, the Swiss-U.S. Privacy Shield Framework Principles have been amended as the “Swiss-U.S. Data Privacy Framework Principles”

This Privacy Policy describes how Freedcamp collects, uses, maintains, and discloses information collected from Users ("User") through all our websites ("Site") and a variety of team productivity, collaboration, and organizational tools available online, including via a mobile application, Gmail add-on, Outlook add-in, Freedcamp FuileEdit application - collectively, the (“Services”) by accessing our services.

This privacy policy applies to the Site and all products and services offered by Freedcamp, INC. If you do not agree with this policy, please do not access or use our Services or any aspect of our Business.

Updates in this Privacy Policy reflect recent changes in data protection law (eg. GDPR) and aims to provide Users a clearer understanding of how Freedcamp manages all User Data.

In Essence

• Freedcamp doesn't have access to your password.
• No one at Freedcamps reads your information.
• Freedcamp is not in the business of selling your data to third parties.
• We don't share your browsing data with third parties.
• We don't share your email data with third parties.
• You can delete the Freedcamp account at any time and it will also delete your data (see the 'Date Deletion' section to learn more).

Applicability

This privacy policy applies to all products and Services (collectively, the “Services”) offered by Freedcamp, INC through Freedcamp.com (collectively, the “Sites”) and our Mobile Applications. In addition, this policy applies to personal data from the European Union that is collected and retained in the United States. This Privacy Policy does not apply to any third-party applications or software that integrate with Freedcamp’s Services or any other third-party products, services, or business.

Data Collected and Received by Freedcamp

Personal Identification Information

We may collect personally identification information from Users in a variety of ways, including, but not limited to, when Users visit our Sites, register on the Sites, and in connection with other activities, services, features, or resources we make available on our Sites. Users may be asked for, as appropriate, name, email address, billing information. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Sites related activities. We will never sell your personal information to third parties and we won’t use your name or company name in any marketing statements without obtaining your permission in writing.

Non-Personal Identification Information

We may collect non-personal identification information about Users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer, and technical information about Users means of connection to our Sites, such as the operating system and the Internet service providers utilized and other similar information.

Other Information

Services Metadata – when Users interact with our Services, metadata is generated to help provide additional context regarding how Users interact with our Sites.

Log Data – Our services will automatically collect information when Users access or use our Sites or Services and records it in log files. Log data may include IP address, previously visited web page addresses, browser type, and settings, time and date when Services were used, browser configurations and plugins, language, and cookie data.

Device Information – Freedcamp collects information about your computer, phone, tablet, or other devices you use to access our Services. This device information includes your connection type and settings when you install, access, update or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.

Location information -  Freedcamp will receive this information from Users during our Account Registration as well as from our vendor partners to approximate your location.

Project information – Freedcamp is a work collaboration tool, therefore any User-generated data by use of our Services will be collected and stored by Freedcamp, and vendor partners. Collected data includes, but not limited to, data that Users post, send, receive, or share. These include any files or links that User upload to our Services. Project data will only be accessible through authorized accounts or the User's designated account and can only be viewed, or altered, by Users assigned to such projects. Freedcamp will never share, sell, or exploit any Project information unless requested by Project Admins. In addition, we may also inadvertently receive information about such Users from the same project members. For example, a specific User may be mentioned by one of their project members when using our Services.

Web Browser Cookies

Our Site, and/or vendors, may use "cookies" to enhance User experience. User`s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. A user may choose to set their web browser to refuse cookies or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How Freedcamp Use Collected Data

Users are the primary Controllers of User Data. Freedcamp is a processor of User Data and Controller of other certain data. Users who resume the role of Project Admins will have the right to grant or remove access to Project Data to any other Users. Freedcamp will never remove Users from any Projects unless specifically instructed by Project Admins or Users failed to provide payment for Freedcamp’s services (see Terms of Service for additional information). 

Freedcamp collects and uses Users personal information for the following purposes:

1. To personalize User experience
2. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
3. To improve our Site
4. We continually strive to improve our website offerings based on the information and feedback we receive from you.
5. To improve customer service
6. Your information helps us to more effectively respond to your customer service requests and support needs.
7. To administer a content, promotion, survey, or other Site feature
8. To send Users information they agreed to receive about topics we think will be of interest to them.
9. The email address Users provide will only be used to respond to their inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
10. As required by applicable law, legal process or regulation
11. For Billing, account management, and other administrative matters
12. For investigative and preventive measures against Site abuse
13. We use information about Users when granted consent for a specific purpose not listed above. For example, we may publish testimonials or feature customer stories to promote our Services. We will always ask for consent prior to posting any information for promotional purposes.

Sharing and Disclosure of Information

Freedcamp will only disclose or share User information for the following purposes:

1. User’s Request: Freedcamp will share all User Data based on the User’s request and instructions.
2. Project Collaboration:  Users can create content, which may contain information about themselves or other Users, and grant permission to others to see, share, edit, copy, and download that content. Some of the collaboration features of the Services display some or all of your profile information to other Service Users when you share or interact with specific content. Similarly, when Users join a project, your name, profile picture, and contact information and will be displayed in a list for other project members so they can find and interact with you.
3. Legal Compliance: If requested by legal Authority, Freedcamp may disclose User information that we determine to be in accordance or required by any applicable law
4. Enforcement: Freedcamp also reserves the right to disclose User information to investigate, prevent, or take action against illegal activities, suspected fraud, or situations involving a physical threat to any such persons.
5. Consent: Freedcamp may share User information with other 3rd parties in instances when we have Users’ consent to do so.
6. Third-Party Service Providers and Partners: Freedcamp works with third-party service providers and partners to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for Freedcamp, which may require them to access or use User information. If a service provider needs to access information about Users to perform services on Freedcamp’s behalf, they do so under instruction from Freedcamp, including abiding by policies and procedures designed to protect User information. Freedcamp will have certain liability under the Data Privacy Framework (please see below) if both 1) the 3rd Party Partner processes any personal data in a manner inconsistent with the Data Privacy Framework and 2) Freedcamp is responsible for the event giving rise to the damage. Please check this page for a list of Freedcamp's partners.
   • Services Users link to their account: Freedcamp receives information when Users enable any 3rd party apps or integrate a 3rd party service with our Services. For example, if Users log into our Services using your Google credentials, Freedcamp will receive your name and email address as permitted by the User’s Google profile settings for authentication purposes. Users and project members may also integrate our Services with other 3rd party services to allow you to access, store, share and/or edit content from a 3rd party through our Services. For example, Users might authorize our Services to access and display files from a 3rd party document-sharing service within Freedcamp. Information that Freedcamp receives when Users link or integrate our Services with a 3rd party service depends on the settings, permissions, and privacy policy controlled by that 3rd party service. We strongly suggest that Users thoroughly review privacy settings and ToS from any 3rd party services in order to fully understand what type of data may be disclosed or shared with Freedcamp.
   • Operational Partners: Freedcamp works with 3rd parties who provide billing, support technical services to deliver and implement solutions to our Users. Freedcamp may share User information with these 3rd parties in connection with their services, such as to assist with billing cycles, to provide localized support, and to provide customizations work. Freedcamp may also share information with these 3rd parties where Users have granted Consent to share any information, for example, technical support services.
   • 3rd Party apps: Users may choose to add new functionality by enabling 3rd party apps to Freedcamp’s Services. In doing Users may be providing these 3rd party apps access to personal information about you such as name, email address, and project data you choose to use in connection with those apps. 3rd party app’s Privacy Policies and ToS are not controlled by Freedcamp, and Freedcamp’s Privacy Policy does not extend coverage for any 3rd party apps and how they handle your personal information. Freedcamp strongly encourages Users to review all 3rd Party Privacy Policies and ToS before connecting them to our Services. If Users object to information being shared with these 3rd parties, please disable the app immediately.
   • Links to 3rd Party Sites: Freedcamp’s Services may include links that direct you to other websites or services whose privacy practices may differ from ours. What you submit to these 3rd party sites are governed under their Privacy Policies and is not covered by Freedcamp’s Privacy Policies.
   • 3rd Party Widgets: Our Services may contain widgets and social media features, e.g. the Twitter "tweet" button. These widgets and features collect your IP address and may set a cookie to enable the feature to properly function. Widgets and social media features are either hosted by a 3rd party or hosted directly on our Services. User’s interactions with these features are governed by the privacy policy of the company providing it and not governed by Freedcamp’s Privacy Policy.

The operations of Freedcamp do require our employees to have access to systems which store and process User Data. This primarily serves the purpose of problem diagnostic or troubleshooting. For example, in order to diagnose a problem Users may have with Freedcamp services, our Employees may need access to your User Data. All employees are prohibited from viewing User Data for any reason unless absolutely necessary to do so.

Data Deletion

When Users delete their account(s) there are different scenarios of how data deletion will be treated as described below:

1. If you were not invited to any other projects owned by other Freedcamp User then your data can no longer be accessed by you or any other Users that you invited to Freedcamp. Complete data deletion will occur post 90 days. Please see “Data Retention” below for additional details regarding 90-days data retention.
2. If the User does not own projects and was only invited to other Freedcamp User’s projects then your specific contribution in other projects will remain, but your personal information will be deleted. Freedcamp will make every effort to mask any personal information remaining, for example, your contribution to someone else’s project will be listed as “First Name, Last Initial” with no connection to your deleted personal information such as email, phone numbers, etc.
3. If you own projects and were participating in other Users’ projects, then Freedcamp’s Data Deletion and Data Retention will apply to each category described in sections (1) and (2) above.

Users, at any time, may request a deletion of their personal data. If such request is made, data are deleted based on points 1, 2, or 3 as noted above and will remain in backups and life-cycle we maintain to ensures we do not store data inside backups for more than 90 days. Users may email legal@freedcamp.com to request data deletion. However, if Users require the deletion of their data, we strongly suggest Users delete their account as this will help initiate the process as stated in points 1, 2, and 3 above. 

IF Users fail to make payment for any premium plans, Freedcamp will remove all paid features and return Users to the Free Plan. Please see section 7.5 of our ToS for User inactivity under the Free Plan. If Freedcamp deletes an account due to inactivity, the above scenarios will apply.

Data Retention

Information storage and security

Freedcamp uses data hosting service providers in the United States to host collected information, and we use technical measures to secure all data. Despite the thorough security measures and safeguards that Freedcamp implements to protect data, no security system is impenetrable and due to the inherent nature of the Internet, Freedcamp cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. Freedcamp has policies in place in case of such a situation and will respond to requests about this within a reasonable timeframe. Freedcamp also provides Enterprise customers who selected the 'private cloud' option to host their isolated and branded Freedcamp environment in any region supported by Amazon Web Services. Please contact sales@freedcamp.com for more information.

How long we keep information

How long we keep the information we collect about you depends on the type of information, as described in further detail below. After such time, we will make every effort to delete your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

• User Account information: We retain User information until the User deletes their account(s), which then we will continue retaining the data for up to 90 days after account deletion. Freedcamp maintains this practice due to the following reason:
  • In the event that the User’s account has been compromised and purposely deleted. Freedcamp will help maintain and restore data once the situation is rectified
  • An account was mistakenly deleted by Users. In such an event, Freedcamp will be able to restore data for Users.
  • Various data storage systems and backups have different lifecycle policies which are held for a maximum of 90 days. For example, our database backups are encrypted, incremental, and full re-cycle in 30 days. It is impossible to erase User data inside up to 1-minute precision encrypted incremental backups.
  • If the User initially canceled their account and requested but later change their mind. A user will be able to have all data restored if an account is reactivated within 90 days after initial account cancellation.
  • Freedcamp may also retain some of the User data as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies any specific Users, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about any Users.
     
• The information you share on the Services: If the User’s account is deactivated or disabled, some of the User information and the content that Users have provided will remain in order to allow other Project members or other Users to make full use of the Services. For example, we continue to display comments and content you provided to boards or cards. Freedcamp will hold User data up to 90 days after account cancellation in case Users will renew again within that time frame.
   
• Marketing and Promotional information: If Users have elected and provided consent to receive marketing and promotional emails from Freedcamp, we retain information about Users' marketing preferences unless asked specifically to delete such information. Freedcamp retains information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Security

We take the security of your data very seriously at Freedcamp. As transparency is one of the principles on which our company is built, we aim to be as clear and open as we can about the way we handle security. Our security practices are published here.

Age Limitation

Freedcamp does not allow the use of our Services or Sites to anyone younger than 16 years old unless Consent is provided in writing by a legal guardian. Freedcamp will make the utmost effort to prohibit the use of our Site by anyone not over the legal age. Should Freedcamp learn that anyone under 16 has unlawfully provided us with personal data, Freedcamp will take the necessary steps to delete such information.

Changes to Privacy Policy

Freedcamp has the discretion to update this privacy policy at any time. When we do make changes, we will post a notification on the main page of our Site and send you an email. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

California Consumer Privacy Rights (CCPA)

Freedcamp complies with the California Consumer Privacy Act (referred to in this Privacy Policy as “CCPA”) as set forth by the State of California. If the CCPA applies to your personal information this Privacy Policy provides you with information regarding how to receive information about our privacy practices, as well as request access to, and deletion of, your personal information.

Freeedcamp does not sell the personal information we collect. We only share your personal information as described in this Privacy Policy. For detailed information about the personal information we collect, and the categories of sources of such information, please see the “Data Collected and Received by Freedcamp”. We collect this information for business purposes set forth in the “How Freedcamp Use Collected Data”. We share this information with the categories of third parties as set forth in the “Sharing and Disclosure of Information” Please note that we do use third-party cookies as further set forth in the “Web Browser Cookies”

California consumers may make a request pursuant to their rights under the CCPA by contacting legal+dataprotection@freedcamp.com. Upon receiving a request, we will verify your request using the information associated with Freedcamp Services, including your email address. Government identification may be required. A consumer can also designate an authorized agent to exercise these rights on the consumer’s behalf.

 EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) 

Compliance

Freedcamp Inc, a U.S. entity, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Freedcamp, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Freedcamp, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Freedcamp Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the Submit a case page to file a complaint.  The services of JAMS are provided at no cost to you.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Freedcamp Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Freedcamp Inc. at:

legal+dataprotection@freedcamp.com or by mail at

Freedcamp, Inc.
3066 Foothill Rd
Santa Barbara, CA 93105, USA
+1 (805) 245-8713

U.S. Federal Trade Commission

Freedcamp’s Data Privacy Framework compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Arbitration

Users may invoke binding arbitration for any unresolved complaints/disputes, however, before initiating such arbitrations, residents of a European country participating in Data Privacy Framework must first:

1. Contact Freedcamp and give us a chance to resolve any issues;
2. Seek assistance with JAMS, our independent recourse mechanism;
3. Contact the U.S. Department and provide them with adequate time to resolve the issue.

If the User invokes binding arbitration, each party will be responsible for its legal fees. Please be advised that pursuant to the Data Privacy Framework, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Data Privacy Framework Principles with respect to the resident.

Data Protection Officer

Please contact Freedcamp's Data Protection Officer for any questions related to our Privacy Policy.

legal+dataprotection@freedcamp.com or by mail at

Freedcamp, Inc.
3066 Foothill Rd
Santa Barbara, CA 93105, USA
+1 (805) 245-8713

User Rights

Users have certain statutory rights in relation to their personal data. Users may have the right to request to rectify or delete any personal information stored on Freedcamp.

Freedcamp will offer EEA and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt out of such uses of their personal information by contacting us at the following:

legal+dataprotection@freedcamp.com or by mail at

Freedcamp, Inc.
3066 Foothill Rd
Santa Barbara, CA 93105, USA
+1 (805) 245-8713

Freedcamp will provide Users an option to export their data. Freedcamp does include this option on 3 of our paid plans(monthly, weekly, daily). Users on plans which do not provide a data exportation tool can export to XLS whenever possible or start a trial on plans which include backup, wait for the backup to be completed, download it and delete their account afterward. Please email legal@freedcamp.com for assistance.

References

Freedcamp's Terms of Service

This document was last updated on December 28, 2019