PRIVACY POLICY
At The Freedom Geek, we take online privacy seriously and we respect the concerns of our community. In this policy, we describe our privacy practices with regard to information we collect to help you make informed decisions about how you share information with us.
Overview
You may click on any title to jump to a section.
Who are we?
 The Freedom Geek Ltd is a private limited company registered in England. Our company number is 10679811, and our registered office is at 80 Compair Crescent, Ipswich, Suffolk, United Kingdom, IP2 0EH. Our VAT number is GB392505881.
 Imogen Cook is the Company Director and we have been in business since 2017. The Freedom Geek specialises in helping small business owners and startup entrepreneurs find (and work with) smart virtual assistants from the Philippines.
Our values about personal information
 We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear.
This Policy explains how we do that – when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure.
 We’ll keep this straightforward and in case you do not want to read through all the details now, we can be clear up front.
 We don’t sell, rent or trade email lists with anyone else.
 This Policy is split into sections depending on who you are:
 Section A is for everyone and includes information about cookies on our websites.
 Section B is for you if you are or work for a business prospect.
 Section C is for you if you are a client or a client contact.
 Section D is for you if are a virtual assistant.
 Section E is for you if we have information about you purely because we are providing services to a client.
 Section F is for you if you are a supplier, associate, or affiliate.
Section A: For everyone
 Whoever you are, we intend to use your information to make things work smoothly for you in your experience of dealing with us. If that’s not how it turns out for you, please make sure to give us a shout. It’s best to put things in writing, which you can do by email to talktous@thefreedomgeek.com.
 This Privacy Policy is up-to-date, last edited in January 2022. We keep this Policy under regular review and we may revise it as needed. Please check back from time to time to make sure you have the latest information.
 In this Policy, the following words are used, and what they mean:
 “personal data” - any information about an identifiable living human being.
 “process” - we “process” your personal data when we do anything with it, which might include: collecting, recording, organising, storing, adapting, altering, retrieving, using, combining, disclosing, or deleting it.
 “special category data” - this is personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, health, genetic or biometric data.
Our general approach to personal data
 We’re committed to protecting your privacy, and honouring your legal rights to control how we use your personal data.
 We only collect and use personal data when we need to:
 because you have asked us to do something (for example, send you newsletters);
 so that we can reply to queries or complaints;
 to develop and manage our business relationships;
 to help grow our business and fulfil our contracts;
 to provide services to clients;
 to meet our legal obligations.
 We try to make sure the information we hold is accurate and up to date, and is no more than we need to have.
 If we are processing information about you purely because we are providing services to others, please refer to Section E.
 If you have any questions or concerns about our use of your information, or how we have responded to any request about your personal data, please take it up in the first instance by emailing talktous@thefreedomgeek.com.
 If we can’t sort it out, the official authority here in the UK is the Information Commissioner, and you can raise your concerns with them here.
Downloads, newsletters and services
 If you contact us and ask us to send you information, or download, or purchase a service, we will put your details on our sales and marketing database and send you what you asked for. (We use Capsule CRM, and their privacy policy is here.)
 If you asked to be subscribed to a particular newsletter or sequence of updates (or subscribe yourself) you will be added to that list. You may need to reconfirm your subscription before anything is sent. Any automated email sent to you will have an unsubscribe option on it that can be triggered at any time.
 We hold your information for our newsletter lists in ActiveCampaign. We gather statistics around email opening and clicks using industry-standard technologies to help us monitor and improve our e-newsletter. For more information, please see Active Campaign’s privacy notice here.
 We use automations (little sequences of emails that start when you ask for something in particular) to send you the information you asked for, to send you documents and programmes you bought and to administer services you have subscribed to. A lot of our onboarding for new services is by emails that send you hints and tips and little videos on ‘how to’. You can unsubscribe from these at any time, but they don’t go on for that long and you might want to wait for all the information as most people find it useful. Unsubscribing from some lists may also affect your access to your onboarding and training zones that support your purchase.
 We monitor who reads our mailing and automations, how many times, and which links you choose to use and read. We use this information to increase the content’s level of interest, and help us improve what we send. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails from us. From time to time, we contact individual email newsletter subscribers but it is extremely rare.
 We ask our own sales and marketing people (both internal and external) to contact potential clients from time to time. This is normally because you have requested a call, or because we are actively trying to let you know about something you may benefit from. Sometimes the law changes and you need to know what happens next.
 Our services are designed to be business to business. We are not a hard sell or cold calling based organisation but prefer to build long-term relationships with satisfied and relaxed clients.
Social media
 We have an active presence on social media, including Facebook, Instagram, Twitter, YouTube, and LinkedIn. Click the name of the platform for a link to their privacy policy.
 If you ‘like’ any of our posts or ‘follow’ us, we can make ourselves aware of who you are from the information that you publish in your profile on the relevant platform. Your information is held by the platform and is subject to their data policy – we don’t control those. You can find a link to the privacy policy for each of the social media platforms by clicking on their name above.
 Your replies to us, messages you send us, and your other activity linked to our posts may be seen by members of our staff and by our associates. Our contracts with them hold them to high standards of protecting your information.
Who can see or use your data?
 We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes. If at any point we decided to exchange lists with another organisation, we would ask you to ‘opt-in’ to such a system. Our continuing silence means we are not doing so.
Data location and platforms
 Like many businesses, we do not have any tailor-made software – we use mainstream packages for everything from our client records, to email, to accounting.
 This means that much of our data is held in services in the USA or UK. We have picked mainstream suppliers with appropriate security standards.
 Special category data (about your health, orientation, beliefs etc) is rarely held by us, and if it is, it is normally part of providing legal advice. We keep that data in Microsoft and Google systems that keep their servers predominantly in the EU. We do not routinely collect this data about anyone.
People
 We have an outsourced support team for our own business. This may include Virtual Assistants, Web Designers, IT support, Sales and Marketing, Accounting and more. Those support services have limited access to your data – only where the service they provide to us means they need it.
 For example, if you want to set up a meeting, our diary VA needs to know your email address in order to sort out a date. If we invoice you, our Accountant needs to see the invoice in order to sort out the books.
 Our outsourced team use our software to access any data they need. We do not permit copying or sharing by the team and actively monitor for any potential breaches.
 Your information/advice is held in the strictest confidence. Our team is contracted to strict confidentiality clauses and we monitor and restrict their data usage. We only use mainstream software and we use the most secure login options available to us.
 We restrict who can export or download data that is held to a limited number of individuals who are authorised to back up data.
 If you want to know who is on our team, please email and ask us. 
How long do we keep your data for?
 If you unsubscribe from our newsletter list, your unsubscribe is recorded so that we do not continue to send newsletters to your email address.
Prospects
 We find that people come back to us a long time after our initial contact, and sometimes after things have been quiet between us for a very long time. However, we do like to be able to respond appropriately and intelligently to old connections, so we generally keep your information on our CRM system for 3 years from our last point of contact.
 If you have contacted us and signed up to a mailing list but never purchased from us, you will remain on the list you joined until you unsubscribe from that list. We clean our lists from time to time and unsubscribe people who not ever read anything from us. But in order to avoid adding you again by mistake, unsubscribes are kept on an unsubscribe list.
Clients and suppliers
 We have a long-term and discreet relationship with most of our clients. We also offer legal advice and support For that reason, we retain information for 10 years from the last point of contact. This allows us to have financial records going back far enough to satisfy HMRC, advice records going far enough back to satisfy our insurers. Our clients often come back to us for information they have forgotten or can no longer find.
Want to see what we hold on you?
 If you want to know what information we have about you (if any) email talktous@thefreedomgeek.com and give us your name, email address(es). Provided we can legitimately disclose the information to you (see section E), we will happily do a search and send you screenshots of what we have.
 If you are not happy with being on any of our lists you can simply unsubscribe. If you want to be removed from our customer records, please let us know.
What are your rights?
 You have the right to know what information we have about you, and to amend it if it is inaccurate.
 If you feel for some reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action.
 Your rights with respect to your personal data are, in summary, to be informed what processing is taking place, to have access to your data, rectification, erasure, restriction, portability, objection, and relating to automated decisions. These rights are detailed here.
Our basis of processing
 Signing onto our newsletter list is by your consent – and when you withdraw your consent, we stop that processing your data.
 Apart from that, the information we hold is based on our needing the information to run our business and provide our products and services – either so we can perform our contract with you, or because we have a legitimate business interest in processing your data.
 In a few situations, we are processing personal data because we are under a legal obligation to do so. This principally relates to our business, accounting and tax records.
 You have a “right to be forgotten” – but that does have some legal limits to it. If you want us to remove information about you, let us know. If you have been a client, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s requirements.
 If you want to know what information we have about you (if any), email us at the email address set out above and give us your name and email address(es).
Section B: Prospects
 Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us.
 Typically, we are collecting names, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our products or services or a relevant contact for our business. 
 See also the general notes above, about what happens if you sign up to our newsletter, or engage with us on social media.
 Sometimes our contact management systems let us know you have a LinkedIn profile or Facebook page or Twitter account. If we are in contact via those mediums, we may add that to your customer record so we remember to check in those places for messages from you. If your account details are private we will not see them.
 If we email you individually using our own email system, or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored. We use Microsoft Outlook email, and our emails are held on their servers. [Their data privacy policy is here.]
 Our outgoing emails are automatically logged into our CRM system, and we aim to collect information there that is relevant to establishing or continuing a business relationship. Our CRM system is Capsule, and their privacy policy is here.
 We currently keep individual emails from and to you indefinitely, so we have a record of our interactions, queries, and how we resolved them. But our central records are removed after three years (see above) if we do not do any business together.
 We do not routinely keep special category data. If we have any, it was supplied or made publicly available by you.
Section C: Clients
 Once you become a client, we will collect further information from you.
 This will include the information we collect from Prospects (above). We collect your email address, phone number, and postal address so we can provide what we have contracted to, invoice you, and keep proper records of our business relationship.
 We process your data to support the delivery of the goods and services you have bought. We keep records of the services provided to you, and information you give us, so we can support you when needed and advise you of any additional products or services you may need or may be appropriate for you.
Third party data
 As well as your own personal data, we understand that you may need to provide us with personal data relating to your employees, your workers, or third parties – depending on the services we are providing to you. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
 This may necessarily include special category data – for example when we are advising on discrimination issues. We maintain high levels of security and confidentiality with respect to data you supply to us.
Financial and credit details
 We do not receive or store your credit card details. Credit card payments are handled by an external secure processor in accordance with their data security policies. We do not take telephone orders and the only way to pay us by credit card is online via that secure processor. We receive limited information from our processor for us to tie up your payment with your invoice.
 We do not routinely keep credit scores nor use credit reference agencies.
 When you pay us by BACS or direct transfer, we receive limited information about you from our bank, usually the name of the person who paid us, how much, and the reference number.
Section D: Virtual Assistants
 Once you apply as a virtual assistant, we collect further information from you.
 This will include the information we collect from Prospects (above). We also collect the following information so we can run checks and make sure you are eligible and in good standing to provide your services.
 Personal identifiers, contacts, and characteristics (for example, your name and contact details)  
 Social media accounts and personal/business websites
 Education and employment data
 Identification and government documents
 Work equipment and devices
 If hired to work with a client, your bank information and postal address
 We will share this information with our clients whose requirements match your credentials and with whom you would like to provide services. 
 We will share personal information with any law enforcement or other authorities if required by applicable law.
Third party data
 As well as your own personal data, we understand that you may need to provide us with personal data relating to your references or third parties – depending on the services you are providing. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
 This may necessarily include special category data – for example when we are advising on discrimination issues. We maintain high levels of security and confidentiality with respect to data you supply to us.
Financial details
 We will ask for your bank details when you are hired. The details will be forwarded to the client to make payments to you for your services.
Section E: Third Party Information
 When we are processing data about you because it is necessary for us to do so to provide services to a client, depending on the circumstances we may be acting as ‘data processor’ (and operating under the banner of our client’s data privacy policy), or we may be the ‘data controller’ (and operating under our own privacy policy).
 If our client is the data controller, we will act as directed by them.
 If we are the data controller, we will act in accordance with your statutory rights, subject to the exclusions and exemptions that may well apply in the circumstances of our processing of your data because we will be giving advice and providing legal services to our client.
 However, please be reassured that we operate under strict confidentiality obligations, and maintain strict security protocols with respect to data we hold.
Section F: Suppliers, Associates and Affiliates
 We collect information on potential and actual suppliers and associates. This is mostly provided by you, but we do add to it the same kind of data we use for Prospects (see above).
 If you become a supplier or associate we keep a copy of the contract between us and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
 We keep a record of the work you undertook for us along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
 This information is all needed to manage the contract between us, support our client relationships, and manage our supply chain.
 If you are an affiliate, your affiliate data is held in accordance with this policy and our affiliate agreement. We will ask you for information when you apply to be an affiliate, and that will be processed to administer the affiliate scheme.
In Conclusion
 If you have any queries or comments about our handling of your personal data, please email us at talktous@thefreedomgeek.com.
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