1. Introduction
This website, including all underlying pages and the information contained thereon (together referred to as the “Website”) is being offered to you by the FreeMove Alliance (“FreeMove”). FreeMove has its registered office at Basisweg 10, 1043 AP Amsterdam, Netherlands, and is listed in the Commercial Register of the Chamber of Commerce under file number 34199114.
The purpose of this Privacy Policy is to explain how FreeMove treats your personal data. FreeMove is committed to safeguarding the privacy of its customers and visitors to its website. Any personal data is held securely and treated with the utmost care. All processing of personal data is performed in compliance with the requirements of the General Data Protection Regulation (EU) 2016/679 (GDPR).
2. What personal data does FreeMove hold?
FreeMove may (directly or indirectly) receive and hold different kinds of information about you:
| Data category | Purpose | Legal basis |
| Usage data regarding the FreeMove website (e.g. storing cookies at the users’ computers, collecting users’ IP addresses). | Enhancing customer experience, improving the content and structure of the website | Consent [GDPR Article 6 (1)(a)] |
| Contact details (such as name, phone number, email and postal address) for you or for others (e.g., principals in your business) | – Customer management (i.e. management of the delivery of offers, contracts, orders and products or services, providing customer support, processing requests and inquiries, prospecting potential customers)
– Vendor management (i.e. management of orders and payments of vendors, prospecting possible vendors) – Product and service management (i.e. updating and enhancing FreeMove’s systems and portfolio of products and services, assisting customers and vendors in future dealings, maintaining and enhancing the safety and security of our products) |
The legitimate interest [GDPR Article 6 (1)(f)] of the controller (i.e. FreeMove) and third parties (i.e. FreeMove’s customers or partners and their representatives), i.e. the facilitation of the sales process (including pre- and after-sales activities, as well). FreeMove encourages its customers to make sure that their employees involved in the sales process get familiar with this Privacy Policy and are aware of such processing of their contact details. |
| Information used to create your online account (such as username, password and security question and answer) | Enabling access to the information and services provided via the website | Contractual necessity [GDPR Article 6 (1)(b)] |
| Contact details for marketing (e.g. in email form) | Customer and partner management, e.g. provision of updates on FreeMove products and services, events, programs, and promotions, conducting and facilitating surveys and market research initiatives; administering, enhancing, improving and developing products and services | Consent [GDPR Article 6 (1)(a)]
You are free to unsubscribe from FreeMove notifications and emails at any given time. In order to do so, you may contact FreeMove by clicking here. |
| Employment information | Enabling operation of the FreeMove organization | – Contractual necessity [GDPR Article 6 (1)(b)]
– Legal obligation [GDPR Article 6 (1)(c)] |
On top of the above and depending on the respective purpose (e.g. accounting, auditing, billing activities), several national and industry-specific regulations stipulate different data retention periods for the above sets of data as legal obligation. For example, the very limited amount of personal data FreeMove holds about its customers’ and partners’ contact persons is typically retained until the end of the applicable, statutory archiving period for the respective document containing such data.
COOKIES:
Cookies are bits of electronic information that a computer user’s browser and operating system stored on the user’s computer hard drive. FreeMove may use Cookies to enhance your experience and to improve the content and structure of the website. Specifically, we use Cookies on www.freemove.com for the following purposes:
- Analytical Purposes: We use these Cookies to analyze user activity in order to improve the website.
- Functional Purposes: We use these Cookies in order to store certain user preferences on our website.
- Marketing purposes: We use these Cookies to display ads that are relevant for You.
You can anytime set your browser to prevent these Cookies being stored or to delete the Cookies at the end of your Internet session. However, please remember that in this case you may not have access to the full range of functions offered by our websites.
You can withdraw your consent to use of the above Cookies at any time, just click here !
3. What rights do data subjects have?
You have the right to request information (GDPR Art.13-14) about and access (GDPR Art.15) to your personal data, as well as to request rectification (GDPR Art.16) if your personal data is inaccurate. Under certain conditions, for instance, if the processing is not necessary for the purpose anymore, you may even have the right to request the erasure (GDPR Art.17) of your personal data or the restriction (GDPR Art.18) of the processing, for example, until the question of necessity is clarified.
Whenever personal data is processed based on the legitimate interest of FreeMove or third parties, you have the right to object (GDPR Art.21) against such processing on grounds relating to your particular situation. Accordingly, where FreeMove processes your data based on your consent, you have the right to withdraw such consent (GDPR Art.7) anytime, with effect for the future.
Please note that FreeMove does not carry out any processing giving rise to the rights related to automated decision making (GDPR Art.22) or data portability (GDPR Art.20).
Of course, you also have the right to lodge a complaint (GDPR Art.77) with the supervisory authority if you consider that the processing of your personal data infringes the GDPR.
4. Where is personal data processed?
Your data is usually processed within the European Union, mainly in the Netherlands (where FreeMove is registered) and in the countries where the four FreeMove members are headquartered (France, Italy, Germany and Sweden). Depending on our customers’ international footprint, in order to facilitate the sales process and the provision of the services rendered by FreeMove or the National Operators, personal data may be transferred to our partners and other third party service providers located outside of the European Union and the European Economic Area.
If we transfer your information internationally, we will make sure that it is done in compliance with the legislation in force, and your information is properly protected.
Available safeguards for such data transfers include adequacy decisions adopted by the European Commission (e.g. in the case of Switzerland), binding corporate rules (e.g. Deutsche Telekom‘s BCRs) or the use of standard contractual clauses issued by the European Commission and signed by the contracting parties in each case.
5. Who may receive your data?
Recipients of your personal data may include:
- members and partners of FreeMove (such as external consulting firms or national telecom operators;
- data processors, i.e. third-party service providers processing personal data exclusively on the instructions of FreeMove and adhering to strict technical and organizations measures;
- other recipients, such as relevant authorities as the disclosure of personal data may be necessary under legal, statutory or regulatory obligations.
6. Other websites and partners
FreeMove uses website links to improve this Website. These links are clearly identified to make you aware that you are leaving the Website. Please be mindful of the fact that these websites are not owned, operated, controlled or maintained by FreeMove. They are operated by other companies and organizations. FreeMove is not and cannot therefore be held responsible or liable for any personal data you choose to disclose through these websites. FreeMove recommends that you consult the individual privacy policies of these websites in order to be aware of the way these websites process your personal data.
FreeMove also co-operates with multiple partners. As for the personal data handled by such partners, for example, the national telecom operators, please refer to the privacy policies of those companies.
7. Will this policy ever change?
The FreeMove Privacy Policy sets out how FreeMove treats your personal data. Because FreeMove constantly updates and reviews the services it provides, it may be necessary for FreeMove to change the way it uses your data. FreeMove reserves the right to do so. FreeMove furthermore reserves the right to make amendments to this Privacy Policy at all times and without prior notification thereof. Please check this website regularly for the latest version of this Privacy Policy.
This Privacy Policy was last updated on 11 June 2019.
8. How to contact us?
For any questions or suggestions regarding this Privacy Policy, please contact FreeMove here.
9. How to contact the supervisory authority?
Should you wish to lodge a complaint or if you feel that FreeMove has not addressed your concern in a satisfactory manner, you may contact the lead supervisory authority of FreeMove.
Address:
Basisweg 10
1043 AP Amsterdam
The Netherlands
Telephone number: (+31) – (0)70 – 888 85 00
