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Ireland
Privacy Policy in accordance with the EU General Data Protection Regulation ("GDPR") for the FREE NOW websites and social media appearances.
Version: April 2022
The following information will give you an overview of the processing of your personal data and your rights according to data protection legislation.
Which personal data is processed is substantively determined based on the services or products you use.
Content
1. Information regarding the Data Controller
2. Definitions
3. General Information
4. Server Log Files
5. Blog
6. FREE NOW Dashboard
7. Cookies
8. Button Tracking
9. Social Media Appearances
10. Data Exchange within the FREE NOW Group
11. Processing in-/outside of the European Union / European Economic Area
12. Your Rights
13. Data Security
14. Data Storage
15. Updates and Changes
1. Information regarding the Data Controller
The data controller as per Art. 4 No. 7 GDPR is:
Free Now Ireland Limited
7-12 Baggot Court
Dublin 2, D02 F891
Ireland
The data controller has a data protection officer. The easiest way to reach our data protection officer is by contacting https://support.free-now.com/hc/en-ie/requests/new or by writing to the foregoing address with the subject “The Data Protection Officer.”
2. Definitions
"FREE NOW Group" consists of Intelligent Apps GmbH, mytaxi Austria GmbH, Free Now Ireland Limited, mytaxi Italia Sr, mytaxi Polska Sp.z.o.o, FREE NOW Portugal Unipessoal Lda, mytaxi Iberia S.L., Clever Tech Srl, Transcovo SAS, Transopco SAS, Transopco UK Ltd.
3. General Information
This document provides you with information on which personal data we process when you visit our FREE NOW websites and our social media appearances and for what purposes we do this.
Please note: If you wish to procure journeys through FREE NOW as a passenger, the "Passenger Privacy Policy" applies, which can be viewed on our website (free-now.com) or via the Passenger App. If you want to procure journeys through us as a driver, you will also be subject to the "Driver Privacy Policy", which can also be viewed on our website (free-now.com) or via the Driver App.
4. Server Log Files
FREE NOW or its webspace provider collects data for technical reasons every time the web pages are accessed:
This data is stored in accordance with Art. 6 (1) f) GDPR for the prosecution of illegal acts and can also be used anonymously for statistical evaluation to optimise our websites.
5. Blog
On our FREE NOW blog you are able to leave comments. The IP address of the author of the comment will be saved in order to identify the author in case of illegal comments. This is in the interest of FREE NOW according to Art. 6 (1) f) GDPR, because we do not tolerate such comments.
6. FREE NOW Dashboard
The FREE NOW Dashboard contains an overview of (i) mediated trips (booking history), (ii) invoices, (iii) fleet management and, in the case of a private hire vehicle, the transport company and (iv) the dispatch center where trips are allocated. The following personal data will be processed in accordance with Art. 6 (1) b) GDPR for the purpose of fulfilling the contract:
Name of the driver, driver ID, status of the driver (e.g. on tour, journey, back to the company headquarters), number of tours made, GPS location, name of the passenger on the invoice, turnover, and in the case of a transport company: contact details, company headquarters, payments and account details.
In order to comply with legal requirements, it is necessary for transportation companies to verify the GPS location when logging into the FREE NOW Dashboard using the geolocation function of the browser. This verification is necessary because transportation companies are only allowed to arrange trips in their business area. The legal basis for processing the GPS location is Art. 6 (1) c) GDPR.
7. Cookies
FREE NOW uses cookies and similar technologies (hereinafter and unless otherwise stated: "cookies") to recognize user preferences and to optimize the design of our FREE NOW websites. This makes navigation easier and makes our FREE NOW websites more user-friendly.
Cookies are small files that are stored on your end device. They can be used to determine whether your terminal device has already communicated with our pages. Only the cookie on your end device is identified. Personal data can be stored in cookies if you have given your consent or if there is another legal reason for doing so.
When you visit our FREE NOW websites, we ask you explicitly for your consent. Most browsers automatically accept cookies. You can also prevent cookies from being stored on your terminal device by selecting Do not accept cookies in your browser settings. You can delete cookies already set on your terminal device at any time. Please refer to the instructions of your browser or terminal device manufacturer for details of how this works. If you do not allow cookies, this can lead to functional restrictions of our offers. However, the basic functions of our FREE NOW websites are still available (e.g. ordering a taxi using the so-called WebBooker).
7.1 Typification of cookies
We divide cookies into the following categories:
Essential Cookies (Type 1)
These cookies are absolutely necessary for websites and their functions to work properly. Without these cookies, services such as the vehicle configurator, for example, cannot be provided.
Functional cookies (type 2)
These cookies make it possible to improve the comfort and performance of websites and to provide various functions. For example, language settings can be stored in function cookies.
Performance cookies (type 3)
These cookies collect information about how you use websites. Performance cookies help us, for example, to identify particularly popular areas of our Internet offering. This enables us to tailor the content of our websites more specifically to your needs and thus improve our offer for you. The information collected with these cookies is not personal.
Third party cookies (type 4)
These cookies are set by third parties on our behalf.
We use the following type 1 and 2 cookies on our websites:
|
Name |
Description |
Type |
|
fe_typo_user |
Frontend login cookie for Typo3 |
Type 1 |
|
cookie_policy_accepted |
Cookie to confirm that privacy policy for cookie have been accepted |
Type 1
|
|
tx_comments_pi1_firstname |
Cookie to store user data for blog post comments |
Type 2 |
|
tx_comments_pi1_last name |
Cookie to store user data for blog post comments |
Type 2 |
|
tx_comments_pi1_email |
Cookie to store user data for blog post comments |
Type 2
|
|
tx_comments_pi1_location |
Cookie to store user data for blog post comments |
Type 2
|
|
tx_comments_pi1_homepage |
Cookie to store user data for blog post comments |
Type 2 |
7.2 Third-party cookies and technologies (types 3 and 4)
a) Google Analytics - Universal Analytics
FREE NOW uses Google Universal Analytics, a web analytics tool developed by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
Google uses cookies. The information generated by the cookies about the use of the FREE NOW websites by the users is usually transferred to a Google server in the USA and stored there.
Google uses the cookie information on our behalf to
FREE NOW uses a version of Google Analytics called Universal Analytics. When a user visits the FREE NOW website, a unique user ID (also known as a user ID) is created and assigned to you. Furthermore, your IP address is stored. This allows interaction data (the type of use of our FREE NOW websites by you) of several sessions (your visits to the FREE NOW websites) to be linked over several devices (so-called cross-device tracking). As a result, we are able to obtain more accurate usage data about our FREE NOW websites. For example, we can then see that a user frequently visits the blog section of the FREE NOW websites both via smartphone and desktop PC. This helps us to constantly optimize the FREE NOW websites and adapt them to your needs. Furthermore, remarketing target groups (audiences) are formed. Thereby certain target groups are formed by visitors of the FREE NOW websites and specific advertisements are then placed for these visitors. We use Google Universal Analytics only with your express consent in accordance with Art. 6 (1) a) GDPR. You can prevent the storage of cookies by adjusting your browser settings accordingly. Please note that in this case you may only be able to use our website to a limited extent. Furthermore, you can prevent the collection of data generated by the cookie and the processing of this data by Google. To do so, download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en Opt-out cookies prevent the future collection of your data when visiting the websites. To prevent Universal Analytics from collecting data across multiple devices, you must opt-out on all systems in use. For more information, please refer to the Google Privacy Policy at: https://policies.google.com/?hl=en.
When using Google Universal Analytics, the following data is processed:
IP address, user ID, origin (country and city), system language set, operating system, device (desktop PC or mobile device), browser type, screen resolution, visitor source (search engine, referring website), downloaded data, videos viewed, advertising banners clicked on, duration of stay on the website and subsequently visited website.
The data sent by us and linked to cookies or user IDs (e.g. user ID) are deleted after 26 months at the latest. Data whose retention period has been reached is automatically deleted once a month.
b) Google Analytics - basic version
If you have not given your consent to use Google Universal Analytics in accordance with Section 7.2 a), we will only use Google Analytics in the basic version with active IP anonymisation, without a user ID and the remarketing target group function (audiences) on the basis of a legitimate interest in accordance with Art. 6 (1) f) GDPR.
The following data are processed in this context:
Abbreviated IP address, origin (country and city), set system language, operating system, device (desktop PC or mobile device), browser type, screen resolution, visitor source (search engine, referring website), downloaded data, videos viewed, advertising banners clicked on, duration of stay on the website and subsequently visited website.
As a result of the activation of IP anonymisation on the websites, your IP address will be shortened by Google within member states of the European Union or in other states which are party to the Agreement in the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
You can switch off the storage of cookies in your internet browser or deactivate them via Google at: https://tools.google.com/dlpage/gaoptout?hl=en. For more information, please refer to Google's privacy policy at https://policies.google.com/?hl=en and https://adssettings.google.com .
The data sent by us and linked to cookies or user IDs (e.g. user ID) are deleted after 14 months at the latest. Data whose retention period has been reached is automatically deleted once a month.
c) Google Conversion Tracking with Adwords
We use Google Conversion Tracking with Adwords from Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") on our FREE NOW websites. When you click on a FREE NOW Google ad, a cookie is stored on your device. These cookies are only stored temporarily for a certain time and do not contain any personal data. It is not possible to identify a person. If you visit the FREE NOW websites and the cookie has not yet been deleted, Google and we can track that an advertisement has been clicked and that our FREE NOW websites have been visited. Different cookies are always generated. Therefore the cookies cannot be tracked. The information thus obtained is used exclusively for statistical purposes. This allows us to know the total number of users who have clicked on an advertisement and then been linked to our FREE NOW websites. We use Google Conversion Tracking with Adwords on the basis of the legitimate interest according to Art. 6 (1) f) GDPR.
For more information, please see Google's privacy policy at: https://policies.google.com/?hl=en . If you do not wish to use Google Conversion Tracking with Adwords, you can disable it at https://support.google.com/ads/answer/2662922?hl=en .
(d) Google Customer Match
We also use Google Customer Match from Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). We use Google Customer Match only with your consent in accordance with Art. 6 (1) a) GDPR. This involves uploading the e-mail addresses of FREE NOW registered customers of the FREE NOW App to Google. From this in turn, target groups can be created. Google then compares whether the transmitted e-mail addresses match existing Google customers. If a match is found, FREE NOW will show these audiences ads/campaigns in Google Search, YouTube, Google Shopping, and Gmail.
The following data are processed in this context: e-mail address.
If, at a later date, you do not wish the processing to take place - e.g. after you have given us your prior consent - please contact us at https://support.free-now.com/hc/en-ie/requests/new
e) Google reCAPTCHA
We use reCAPTCHA from Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") on our web pages to detect bots, e.g. when entering data into online forms. The purpose of reCAPTCHA is to check whether the data input on our websites (e.g. in a contact form) is done by a human being or by an automated program. ReCAPTCHA thus serves to prevent abusive automated entries in web forms and thus to protect the technical systems of the host. For this purpose, reCAPTCHA analyses the behaviour of the web page visitor on the basis of various characteristics. This analysis starts automatically as soon as the visitor enters the website. For analysis purposes, reCAPTCHA evaluates various information, e.g. IP address, time spent on the website or mouse movements made by the user. The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run completely in the background. Website visitors are not notified that an analysis is taking place.
Data processing is carried out on the basis of Art. 6 (1) f) GDPR. We have a legitimate interest in protecting our web offers from abusive automated spying and from SPAM.
For more information, please see Google's privacy policy at: https://policies.google.com/?hl=en .
f) Google DoubleClick
The FREE NOW websites also use the Google online marketing tool DoubleClick from Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). This is used to ensure that you, the user, see relevant ads, to provide us with better campaign performance reports and to prevent you from seeing ads more than once.
Google records which ads are shown in which browser via a so-called cookie ID. Thus, it can be excluded that you receive ads twice.
Google receives the following information: IP address, device identifier, location data and customer-assigned identifiers.
If you are logged in to your Google Account at the same time, Google may be able to associate your visit to our FREE NOW websites with your Google Account. This may also be possible if you are not logged in.
In addition, by using Google DoubleClick, we can understand whether you engage in certain activities on our FREE NOW web pages, for example, when you view or click on an ad on Google or another DoubleClick platform. This allows us to serve ads to you on Google or the relevant DoubleClick platform in a targeted manner through our service.
We only use Google Double Click with your express consent in accordance with Art. 6 (1) a) GDPR.
For more information, please visit Google's privacy policy at: https://policies.google.com/?hl=en. Later, you can switch off Google DoubleClick by setting up your browser or by temporarily disabling it at: https://www.google.com/settings/ads . You can set up a permanent deactivation at http://www.google.com/settings/ads/plugin .
g) Google Tag Manager
We also use the Google Tag Manager of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") on our websites. This tool makes it easier for us to add further services and it is not used to create personalized profiles of users of the FREE NOW websites. For the purpose of troubleshooting, the IP address is processed in this context. We use the Google Tag Manager because of a legitimate interest according to Art. 6 (1) f) GDPR (preservation of the functionality of the FREE NOW websites).
h) Twitter pixel
Furthermore, we make use of the so-called conversion tracking on the FREE NOW websites with Twitter Pixel, a tool of the Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland ("Twitter"). This enables us to statistically record the usage of our FREE NOW websites in order to optimize them. Conversion tracking involves a cookie being placed on your device by Twitter when you visit our FREE NOW websites by clicking on a Twitter ad. Conversion tracking is used to generate statistics and not to identify you personally. Rather, we only want to know which Twitter ads or interactions bring users to our FREE NOW websites. Example: You visit page X and click on a FREE NOW banner ad and then you will be directed to our FREE NOW websites. This allows us to better control the placement of e.g. banner ads and to target specific websites on the Internet. You can find further information on this at https://business.twitter.com/en/help/campaign-measurement-and-analytics/conversion-tracking-for-websites.html. We only use the Twitter pixel with your express consent in accordance with Art. 6 (1) a) GDPR .
You can prevent the storage of cookies by means of an appropriate browser setting. In addition, you can change settings in your personal Twitter account to receive advertising: https://twitter.com/settings/personalization . You can find further information at: https://twitter.com/en/privacy
The following data are processed in this context:
Twitter cookie ID, browser user agent string, browser IP address, website tag ID, timestamp, URL of the page.
i) LinkedIn Pixel
Furthermore, we make use of conversion tracking on the FREE NOW websites with LinkedIn Pixel, a tool of the LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). This enables us to statistically record the usage of our FREE NOW websites in order to optimize them. Conversion tracking involves LinkedIn placing a cookie on your device when you visit our FREE NOW websites by clicking on a LinkedIn ad. Conversion tracking is used to generate statistics and not to identify you personally. Rather, we only want to know what LinkedIn ads or interactions with LinkedIn users bring to our FREE NOW websites. Example: You visit page X and click on a FREE NOW banner ad and then you will be directed to our FREE NOW websites. This allows us to better control the placement of e.g. banner ads and to target specific websites on the Internet.
You can find further information on this under https://www.linkedin.com/help/linkedin/answer/67595
We use the LinkedIn pixel only with your consent according to Art. 6 (1) a) GDPR . You can prevent the storage of cookies by setting your browser accordingly. Please note that in this case you may only be able to use our websites to a limited extent.
The following data are processed in this context: IP address, timestamp, events (e.g. page impressions).
j) Facebook Custom Audiences via the customer list and pixels
On the FREE NOW websites we make also use of the so-called remarketing function of Facebook Custom Audiences of Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). We use Custom Audiences to reach you or specific target groups again after a certain period of time, to exclude certain existing customers and to identify new customers based on website visits (e.g. to form statistical twins / lookalikes). Addressing is done by placing advertisements on Facebook (so-called Facebook Ads) or on partner pages of Facebook. With this we want to address you better and draw your attention to our service. In the Facebook Custom Audiences process, a connection to the Facebook servers is established when you visit our FREE NOW website through a pixel embedded on our FREE NOW websites. When you use the FREE NOW app, your advertising identifier (IDFA or GAID) is sent to Facebook, and when you use the FREE NOW websites, the cookie ID and IP address are sent to Facebook. This tells Facebook that you came to our FREE NOW websites through an advertisement or that you visit our FREE NOW websites. Facebook can then assign the visit to your Facebook account if you are logged in to your Facebook account at the same time. We only use Facebook Custom Audiences on the basis of your express consent in accordance with Art. 6 (1) a) GDPR. You can find further information at: https://www.facebook.com/about/privacy . You can deactivate Facebook Custom Audiences here: https://www.facebook.com/ads/website_custom_audiences/ .
Furthermore, we can, with your consent, manually upload email addresses of FREE NOW registered customers of the FREE NOW app to Facebook. From this, target groups can be created. Facebook then compares whether the email addresses submitted match existing Facebook customers. If there is a match, then FREE NOW ads/campaigns will be displayed to these target groups on Facebook or on partner sites of Facebook.
If, at a later date, you do not wish the processing to take place - e.g. after you have given us your prior consent - please contact us at https://support.free-now.com/hc/en-ie/requests/new
k) Hotjar (used only in the FREE NOW Dashboard)
In order to make the content of the FREE NOW portal dashboard more user-friendly, we use Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St. Julian’s, STJ 3141 ("Hotjar"). Hotjar provides a web analytics service which generates feedback and helps FREE NOW improve the functionality and usability of the dashboard.
For this purpose we process the following personal data:
Hotjar processes personal data exclusively in the European Union. Hotjar may use cookies for this purpose. You can find an overview over all the cookies used in our consent management tool.
The legal basis for the processing is your freely given consent, Art. 6 (1) (a) GDPR, provided through our consent management tool. You are able to revoke your consent at any time through the same consent management tool by clicking on “Cookie Settings” here: https://free-now.com/ie/gtc-privacy-policy-cookies/.
For more information, please see Hotjar's privacy policy at: https://www.hotjar.com/legal/policies/privacy/
8. Button Tracking
a) AppsFlyer
Furthermore, we make use of the so-called button tracking on the FREE NOW websites, a tool of AppsFlyer Ltd, 14 Maskit St., Herzliya, Israel ("AppsFlyer"). This enables us to statistically record the usage of our FREE NOW websites in order to optimize them ("attribution purposes"). Button tracking stores whether a user clicks the app download button. We use button tracking to generate statistics and not to identify a person. Rather, we only want to know if and how often the app download button is clicked. The creation of a personal reference is theoretically possible due to the associated processing of the IP address, but we do not want this nor do we make use of it. Button tracking cannot be switched on and off for technical reasons. Whenever you click the App-Download button on the FREE NOW web pages, button-tracking takes place. If you do not want this, you should not click on the app download button on the FREE NOW web pages. We have included a notice with the app download button and we assume that when you click on the button, you give your consent. The data will then be processed in accordance with Art. 6 (1) a) GDPR.
In this context, the following data are processed:
User agent (OS version, device type, browser language), IP address, operating system.
Further information can be found in AppsFlyer's privacy policy at: https://www.appsflyer.com/privacy-policy/ and under:
If you wish to download or purchase our app without button tracking, you must purchase the app directly from the Apple Store, Google Play Store or similar source.
9. Social Media Appearances
a) Facebook
When entering our Facebook-page (via a link on our website, in our newsletter or directly) you reach the technical platform provided by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland („Facebook“). We would like to inform you that you use the Facebook-page and its functions on your own responsibility. This especially applies for the use of the interactive functions (e.g. comments, sharing, rating).
During you visit on our Facebook-page, FREE NOW basically processes personal data only if you interact with us via the page, e.g. when leaving a comment, press a like-button or sending us a message. The legal basis for this processing depends on the way you use the page. If you send us a contract-related request for example, the processing is based on Art. 6 (1) (b) GDPR. Moreover, according to Art. 6 (1) (a) GDPR your data can be processed with your consent when you like or comment one of our posts or provide content on our page yourself. You can withdraw your consent any time with future effect by deleting the comment or your regarding content. The revocation does not affect the legitimate consent-based processing that was performed until the revocation.
Additionally, we analyze the visits and interactions on our page. For this Facebook creates usage profiles and provides the data in form of page-insights (“page-insights”). Page-insights are summarized data that allows us to get an overview on how users interact with our Facebook-page. For further information please visit: https://www.facebook.com/help/pages/insights.
Please mind that your personal data is not only processed by FREE NOW, but also by Facebook while using and interacting with our Facebook-page. FREE NOW and Facebook are jointly responsible for the processing of insight-data. The respective responsibilities for FREE NOW and Facebook regarding the processing of insight-data are available in the page insights addendum: https://www.facebook.com/legal/terms/page_controller_addendum. How Facebook uses insight-data for its own purposes, to what extent insight data can be matched with certain users, for how long this data is stored and if data resulting from your visit on a Facebook-page is handed over to third parties is solely the responsibility of Facebook.
Regarding the data processing via our Facebook-page, you can not only assert your rights under the GDPR (for further information see Section 12 “Your Rights” of this document) towards FREE NOW, but also towards Facebook. Further details can be found in Facebook’s data policy under: https://www.facebook.com/about/privacy.
Additional to the before-mentioned processing activities, Facebook also processes your data for analysis and advertising purposes, respectively to display personalized advertisements. According to our knowledge, Facebook makes use of cookies, pixels and other techniques which process your usage behavior (even across different devices. This enables Facebook to display target-oriented advertisements on its own platforms and third-party websites, as well. The data collected about you in this context are transmitted to the United States of America and other non-EU countries. Which exact information Facebook receives and how it is used, is generally described in Facebook’s privacy policy. There you will also find ways to contact Facebook directly and information on settings for advertisements. The privacy policy is available under https://www.facebook.com/about/privacy.
The complete privacy policy can be found here: https://www.facebook.com/full_data_use_policy.
Furthermore, Facebook offers users the possibility to object to certain processing activities. More information on this and opt-out-possibilities can be found here: https://www.facebook.com/settings?tab=ads.
b) Links to the social networks Instagram, Twitter, LinkedIn, Xing, YouTube
On our website and in our newsletters we link our accounts on other social media platforms Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; „Instagram“), LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; „LinkedIn“); Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland; „Twitter“), YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; „YouTube“) and Xing (New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany; „Xing“) via the icon of the respective social network. When you click the links or visit our pages on the platform directly, you are on the website of the respective social media platform. The general terms and conditions and privacy policies of the respective social media network provider will apply. We do not receive any information about the content and extent of the data processing performed by the social media network. Information on how the respective social media platform handles your data can be found in the following privacy policies:
We process personal data on our social media pages as far as the user interacts with us directly, by commenting or liking our posts or sending messages. Legal basis for this kind processing is the user‘s consent according to Art. 6 (1) a) GDPR or in case of contract-related requests Art. 6 (1) b) GDPR. As the case may be, we share content on our social media page, if this is a function of the social media platform and communicate with you via this platform. Art. 6 (1) f) GDPR provides the legal basis for this. The processing is performed due to a legitimate interest in public relations and communications.
10. Data Exchange within the FREE NOW Group
For internal administration and standardization purposes, we may transfer personal data of drivers or passengers within the FREE NOW Group. The legal basis for this is our legitimate interest in effective company management, Art. 6 (1) f) GDPR, see also Recital 48 to the GDPR.
10.1 Joint Controller Agreement
FREE NOW has entered into a joint responsibility agreement pursuant to Art. 26 GDPR with other entities of the FREE NOW Group. In this agreement the parties have jointly determined the order in which personal data will be processed for each processing step. The agreement applies between FREE NOW and other entities of the FREE NOW Group.
The purpose of this agreement is to enhance our service level, improve the processing of customer inquiries and to standardize the handling of users' personal data within the entire FREE NOW Group. The parties have jointly agreed on what obligations each party will fulfil under the GDPR.
Despite the existence of a joint controllership, the Parties fulfil the obligations under data protection law in accordance with their respective competences. The Parties shall provide any information referred to in Articles 13 and 14 GDPR to you free of charge in a concise, transparent, intelligible and easily accessible form, using clear and plain language. For this purpose, each Party shall provide the other Party with all necessary information relating to their respective operating range. The Parties shall immediately inform each other about the exercise of your rights and provide the other Party with all necessary information referred to the right of access. Pursuant to Articles 15 through 22 GDPR, you may exercise your rights under the GDPR in respect of and against each of the Parties. However, to speed up the response, we would kindly ask you to contact FREE NOW to exercise your rights at https://support.free-now.com/hc/en-ie/requests/new.
For more information on data processing by Intelligent Apps, please refer to the information provided in the German privacy policy on the free-now.com website.
11. Processing in-/outside of the European Union / European Economic Area
In part, we arrange for external service providers to process your data (e.g. troubleshooting, creation of mailings). To this end it is necessary for us to transmit your personal data to our external service providers for a specified purpose (confined to the purpose in question). We have selected our service providers carefully and engaged them in writing. They are bound by our instructions and we have obtained information about their technical and organizational measures for the secure processing of personal data. We also require that our service providers comply with applicable data protection legislation. We work with service providers from the EU and EEA countries. We have concluded data processing agreements with our external service providers in accordance with Art. 28 (3) GDPR, inasmuch as this is required for the contractual purpose. The transfer to service providers outside of the European Economic Area takes place correspondingly on the basis of decisions by the EU Commission pursuant to Art. 45 GDPR or on the basis of standard EU contractual clauses.
We store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites within the EU.
We do not sell any personal data to third parties.
However, we do reserve the right to disclose information about you if we are legally obligated to do so or if we are asked to surrender it by administrative or law enforcement bodies (e.g. police or state prosecutors).
12. Your Rights
You have the right to obtain confirmation as to whether or not personal data concerning you is being processed by us. Where this is the case, we will give you access to the personal data and the information listed in Art. 15 GDPR.
In addition, you have the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR), subject to the relevant legal requirements. In addition, you have the right to object to the processing under the statutory conditions (Art. 21 GDPR) or to withdraw any consent you have given at any time with effect for the future (Art. 7 (3) GDPR).
In order to assert your rights against us, it is sufficient to contact us at https://support.free-now.com/hc/en-ie/requests/new or a postal letter to the address mentioned under “1. Information regarding the Data Controller”.
In addition, you may at any time lodge a complaint with a competent supervisory authority if you consider that the processing of your personal data infringes data protection legislation (Art. 77 GDPR).
13. Data Security
We have taken appropriate technical and organizational measures to ensure data security, in particular to protect your personal data against access by third parties, as well as accidental or intentional modification, loss or destruction. Such measures are reviewed periodically and adapted in line with the state of the art.
14. Data Storage
The data provided by you to us is only stored for as long as is required to perform the respective purpose for which you have transmitted your data, or inasmuch as it is required for conformity with statutory or official requirements. Personal Data is anonymized by us, in principle, after three years, unless we have a legitimate interest in a longer storage period.
15. Updates and Changes
We retain the right to modify this privacy policy at any time in the future in accordance with the applicable data protection regulations.
