Privacy Policy

EU-U.S. Privacy Shield Statement

Fresh SEM ("us" or "we") participates in the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union member countries. This EU-U.S. Privacy Shield Statement explains how we receive and handle Personal Information from European data subjects ("you") in reliance on the Privacy Shield Framework.

We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with regard to all Personal Information received from the EU in reliance on the Privacy Shield Frameworks. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program and to view our certification, visit here.

Types of Personal Information Collected

Fresh SEM collects information that, alone or in combination with other data, could be used to identify you (Personal Information), such as your email address, name, physical address, telephone number, or employment information. If you make a purchase from Fresh SEM, we will collect and store your billing and credit card information. Fresh SEM may also collect anonymous demographic information which is not unique to you, such as your postal code, age, gender, preferences, interests and favourites (Non-Personal Information). Non-Personal Information is not linked to your Personal Information (for example, your IP address).

Fresh SEM will collect your Personal Information in a number of ways, including when you contact us through the Website, by telephone, post, e-mail or through the other means set out below.

Information you provide when you register for an account
When you register for a Fresh SEM account, you voluntarily give us certain Personal Information, including your:

• email address.
• billing information, if you make a purchase or pay subscription fees. This is required to complete a commercial transaction on the Website.

Automatically collected information
When you visit our Website, we automatically collect information about your computer hardware and software such as your IP address, browser type, domain names, access times, operating system, cookie information, referring website addresses, pages visited, links clicked, text entered, mouse movements, and Internet Service Provider. We analyse and use this information to better understand how our users use the service, to maintain and improve our service, and in some cases, to publicly disclose aggregated statistics regarding our services.

Use of your Personal Information (Purposes of Collection)

Fresh SEM collects and uses your Personal Information as necessary to perform our contract with you and for our legitimate business interests, including to:

• operate the Website and deliver the services.
• communicate with you about the services you use, as well as respond to requests for assistance, including account verification support if you're having difficulty accessing your account. Fresh SEM will send a welcome email following registration to all registered users. We also periodically send service updates to registered users.
• display user content associated with your account and make sure it is available to you when you use our services.
• understand and improve how our users use and interact with our services.
• publicly disclose aggregated statistics regarding our users use of our services.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. When we process any payment made by you, we process your Personal Information to prevent or detect fraud, including fraudulent payments and fraudulent use of the Website. The legal basis for this processing is compliance with our legal obligations. With your consent, we will send you direct marketing emails from our third party partners.

Disclosure of your Personal Information

We will only disclose Personal Information to third parties:

• when we use vendors, developers and service providers to assist us in meeting business or operating needs, such as providing online marketing services, hosting your Website, communicating with users, delivering and improving our services, e-mail communication, invoicing and payments, customer support services and analytics. These service providers may only access, process or store Personal Information pursuant to our instructions and to perform their duties to us, and in accordance with applicable laws and regulations; or
• when we have your explicit consent to share your Personal Information; or
• when we determine that disclosure is required to protect the rights, property, or personal safety of Fresh SEM and users of the Website, or to respond to lawful subpoenas, warrants, or requests by public or regulatory authorities, or by law enforcement authorities, including to meet national security or law enforcement requirements; or
• if we sell some or all of our business or assets, we may disclose your Personal Information to the prospective seller or buyer of such business or assets, and if the transaction closes, then your Personal Information may be transferred to the buyer.

In cases of onward transfer to third parties of Personal Information of individuals received pursuant to the Privacy Shield Frameworks we are potentially liable.

Your Rights

Under the GDPR, you have various rights in relation to your Personal Information, such as the rights of access, rectification, restriction, objection, portability, and erasure. Please note that these rights are subject to certain limitations set forth in applicable law.
To exercise these rights, please contact our DPO. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise.

Contacting us

If you have any specific data protection queries or concerns, you can address it to Fresh SEM Data Protection Officer at dpo@freshsem.com

How to make a complaint about how your data is processed

If you are dissatisfied with any aspect of how Fresh SEM processes your personal data, you can lodge a complaint with the Information Commissioner’s Office, the data protection regulator in the UK.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113
Email: casework@ico.org.uk

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