Privacy Policy

Freehold Mobile is an application used to own and use the Freehold multi-chain non-custodial digital wallet (the “Freehold Wallet”) and access related services on mobile devices.

This Privacy Policy (“Privacy Policy”) is designed to help you understand our practices regarding the collection, use, and disclosure of certain information, including your personal information, and to assist you in exercising your privacy rights.

Freehold Services are owned and operated by Realio Technologies, LTD (“Realio”, “we”, “us” and “our”). Thank you for placing your trust in us. We know your personal information is important, and we maintain this policy to collect and handle it responsibly.

SCOPE

This Privacy Policy applies to information we gather and process when you use Freehold Mobile, access your Freehold Wallet through an internet-based digital network (“Freehold Web”), and access related services (collectively with Freehold Mobile and Freehold Web, the “Freehold Services”).

INFORMATION WE COLLECT

When you use Freehold Services, we may collect the following kinds of information:

INFORMATION YOU PROVIDE TO US

Account Information. If you download Freehold Mobile and create your Freehold Wallet, you will provide us with personal information (also known as “personally identifiable information” or “personal data” under applicable laws). This may include your username, name password, email address, mobile phone number, or other information necessary to create and maintain your account or profile.

Your Communications with Us. Whenever you request information about Services, request customer service or technical support, or otherwise communicate with us, we will collect personal information, which may include your name, email address, IP address, device type, etc.

Transaction Information. When you convert to or from fiat currency via Freehold Mobile or Freehold Web, you will need to provide a third-party payment processor with your payment information, as well as personal and financial information for anti-money laundering and “know your customer” review (AML/KYC). We do not collect or store any payment card information entered through the Freehold Services or AML/KYC information.

For all transactions, including those conducted using digital assets and currencies only, we may collect your name, the name of the recipient or transmitter, email address, the currency, the name of the asset and the date as part of the transactions taking place on the Freehold Services, and show this information in your account history or transaction history.

INFORMATION COLLECTED AUTOMATICALLY

Private Key and Public Key. When you create your wallet, your private key and public key will be automatically created.

Automatic Data Collection. We may collect personal information automatically as you use the Freehold Services, including when you access your Freehold Wallet through Freehold Web. This personal information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location-based on your IP address), Internet service provider, pages that you visit before, during and after using the Freehold Services, information about the links you click, information about how you interact with the Freehold Services, including the frequency and duration of your activities, and other information about how you use the Freehold Services. Personal information we collect may be associated with accounts or other devices.

Cookies, Pixel Tags/Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Freehold Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect personal information through the Freehold Services. Technologies are essentially small data files placed on your smart phone, computer, tablet, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Freehold Services.

• Cookies. Cookies are small text files placed in visitors' device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Freehold Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Freehold Services that collects information about users' engagement. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on particular content. We may also include pixel tags in emails to understand whether messages have been opened, acted on, or forwarded.
• Analytics. We use service providers such as Google Analytics and may use others to collect anonymized or aggregate information regarding user behavior and user demographics on the Freehold Services. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. You can opt out of Google's processing of data generated by your use of the Freehold Services by visiting https://tools.google.com/dlpage/gaoptout.

HOW WE USE YOUR INFORMATION

We will not do any of the following:

• Collect your private key, except as needed if you elect to use Custody assist;

• Sell your Personal Information;

• Collect financial payment or banking information, however, when you use our fiat on- or off-ramp features these services may necessitate you submitting this information to third-party providers.

We use your personal information for a variety of business purposes, including:

• Providing the Freehold Services or requested information;

• Fulfilling our User Agreement with you;

• Managing your information;

• Responding to questions, comments, and other requests;

• Providing access to certain areas, functionalities, and features of the Freehold Services;

• Answering requests for customer or technical support.

Your information will also be used for administrative purposes such as:

• Direct legitimate interests - marketing, research and development, network and information security, and fraud prevention;

• Measuring interest and engagement in the Freehold Services;

• Improving our products and Services;

• Developing new products and services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities;

• Carrying out audits;

• Communicating with you about your account, activities on the Freehold Services and Privacy Policy changes;

• Preventing and prosecuting potentially prohibited or illegal activities;

• Enforcing our agreements, and

• Complying with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at: https://support.realio.network/hc/en-us/requests/new?ticket_form_id=34562640032795 any time, as set forth below.

Consent. We may use personal information for purposes disclosed to you at the time of collection or with your explicit consent. At any time, you have the right to revoke your consent with respect to our collection, use, or disclosure of your personal information.

De-identified and Aggregated Information Use. We may strip out personal identifiers and use your remaining personal information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

HOW WE USE THE AUTOMATIC COLLECTION TECHNOLOGIES.

Our uses of the automatic collection Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies employed when you access Services that are required to identify irregular behavior, prevent fraudulent activity, and improve security or that otherwise are needed to make use of the Freehold Services.

Performance Related. We may use the Technologies to assess the performance of the Freehold Services, including as part of our analytic practices to help us understand how our visitors use the Freehold Services;

Functionality Related. We may use the Technologies when you respond to our offers of enhanced functionality when accessing or using Services. This may include identifying you when you sign into the Freehold Services and keeping track of your specified preferences or past pages viewed; and

Advertising or Targeting Related. We may use our own Technologies or third-party Technologies to develop and deliver content, including ads relevant to your interests, on the Freehold Services, or on third-party sites. Depending on applicable law, we may seek your express consent to such ads. We do not sell your personal information.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust information include service providers for: (i) the provision of the Freehold Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of technical support and related services. We do so in accordance with applicable law, which may require data processing agreements or addenda.

Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.

APIs and Software Development Kits. The Freehold Services may use third-party application programming interfaces (APIs) and software development kits (SDKs) to provide functionality. APIs and SDKs may allow third parties to collect your personal information, subject to applicable law, to provide more relevant content. For more information about our use of APIs and SDKs, please contact us as set forth below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any personal information we store in association with you to external parties if we believe, in good faith, doing so is required or appropriate for the following purposes:

• to comply with law enforcement or national security requests and legal process, such as a court order or subpoena;

• to protect your, our, or others' rights, property, or safety;

• to enforce our policies or contracts;

• to collect amounts owed to us; or

• to assist with an investigation and prosecution of suspected or actual illegal activity.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal information may be used for due diligence or transferred as part of such a transaction as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

You agree that all personal information processed by us may be transferred, processed, and that may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If you are a resident of the European Economic Area (EEA), Switzerland, or the United Kingdom and provide personal data to us, we will either seek your express consent to such transfer if you are an individual data subject in accordance with applicable law, or we will rely on mechanisms such as the applicable Standard Contractual Clauses.

YOUR CHOICES

General. You may have the right to opt into certain uses of your personal information. Or, based on your type of use or your geographic location, you may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below.

Email Communications. If you receive an unwanted email from us, you can use the “unsubscribe” link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails confirming transfers to and you’re your Wallet or regarding products or Services you have requested. We may also send you non-promotional communications regarding us and the Freehold Services, and you will not be able to opt out of those communications (for example, communications regarding the Freehold Services or updates to this Privacy Policy).

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Depending on your domicile and applicable law, we may seek your express consent to the placement of cookies. Please note that cookie-based opt-outs are not effective on mobile applications. The online advertising industry also provides websites on which you may opt out of receiving targeted ads from multiple advertisers that participate in self-regulatory programs. You can access these and also learn more about targeted advertising and consumer choice and privacy, at https://www.networkadvertising.org/managing/opt_out.asp, https://www.youronlinechoices.eu/ and https://www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS

You have the right to do any of the following:

• Limit the use and disclosure of sensitive personal information: you can direct businesses to only use your sensitive personal information for limited purposes, such as providing you with the services you requested.

• Request restriction to use of your personal information or its processing, including the right to opt in or opt out of the sale and sharing of your personal information to third parties.

• Request correction of your personal information where it is inaccurate or incomplete.

• Request disclosure of: 1) the categories and/or specific pieces of personal information we have collected about you, 2) the categories of sources for that personal information, 3) the purposes of that information, 4) the categories of third parties with whom we disclose the information and 5) the categories of information that we sell or disclose to third parties.

• Access personal information about you consistent with legal requirements. In addition, you may have the right, in some cases, to receive or have your electronic personal information transferred to another party.

• Request deletion of your personal information, subject to certain exceptions prescribed by law.

• Equal treatment: you cannot be discriminated against for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We retain the personal information we have received as described in this Privacy Policy for as long as you use the Freehold Services and as necessary to fulfill the purpose(s) for which it was collected, to provide the Freehold Services, to resolve disputes, to establish legal defenses, and to conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We use appropriate technical, organizational, administrative, logical, physical, and managerial measures to safeguard your personal information against loss, theft, and unauthorized access, use, and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

To the extent permitted by applicable law, by using the Freehold Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Freehold Services. If we learn of a security system's breach, we may attempt to notify you electronically by sending a notice through the Freehold Services or by sending an email to you.

THIRD-PARTY WEBSITES/APPLICATIONS

The Freehold Services may contain links to other websites/applications, and other websites/applications may reference or link to the Freehold Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of, such other websites or applications. Visiting these other websites or applications is at your own risk.

NOTICE REGARDING USE OF BLOCKCHAIN

Transactions to and from your Freehold Wallet will be conducted on the relevant blockchain protocol. Information about your transfers will be provided to the blockchain and may be accessible to third parties due to the public nature of the blockchain. Because of the public nature of entries to the blockchain and because it may be possible for someone to identify you through your pseudonymous, public wallet address using external sources of information, any transaction you enter onto the blockchain could possibly be used to identify you, or information about you. Please note that once your information is uploaded onto or otherwise recorded on the blockchain, it cannot be deleted.

CHILDREN'S INFORMATION

The Freehold Services are not directed to persons under 18 (or to children otherwise protected by applicable law), and we do not knowingly collect personal information from children. We will try to establish that you are at least 16 years old; if you are not, you will be instructed not to misrepresent your age or use the Freehold Services. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child's personal information in violation of applicable law, we will promptly take steps to delete such information.

SUPERVISORY AUTHORITY

If you are located in the European Union, Switzerland or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Policy from time to time at our sole discretion, and such revisions may reflect compliance with applicable law as it changes. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Freehold Services after the new Privacy Policy takes effect.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) PRIVACY NOTICE

This CCPA Privacy Notice applies to California consumers and supplements the Privacy Notice. We do not sell personal information. For purposes of the CCPA, we have collected the following categories of consumers' personal information in the last 12 months:

We use the collected personal information for the following commercial and business purposes: (1) to provide and improve the Freehold Services; (2) for marketing purposes; (3) for fraud prevention and legal purposes; (4) to secure the Freehold Services; and (5) for audit purposes. Personal information within each of the categories may be shared with the following categories of third parties: (1) service providers; (2) business partners; (3) advertising partners; and (4) other users. The categories of personal information are shared for the commercial and business purposes listed above.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

Freehold Services

123 Main Street, 2nd Floor,

Road Town Tortola VG1110

BVI

https://support.realio.network/hc/en-us/requests/new?ticket_form_id=34562640032795

EU DATA PROTECTION OFFICER

VeraSafe has been appointed as Freehold Services’ representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to [email protected] only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

UK DATA PROTECTION OFFICER

VeraSafe has been appointed as Freehold Services’ representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of [email protected] only on matters related to the processing of personal data. To make such an inquiry please contact VeraSafe using this contact form:

https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom