Privacy policy

Effective Date: Feb 08, 2019

Thanks for visiting Freeze! Freeze Debt (“Freeze”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, honesty, and placing you in control. That’s why, here, in our privacy policy, we describe what personal information we collect, what we do with it and your choices and rights.

By using any of Freeze’s Services, you confirm you have agreed to the Terms of Service and read and understood this Privacy Policy and our Cookie Policy.

1. Some key terms

In our Privacy Policy, when we refer to “Users”, we mean our customers who use our Services, including visitors to our site, and users of our mobile application.  

2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect and use for our own purposes (i.e., where we are a controller), such as your site traversal and information about how you use and interact with our services, app, and website. This also includes information you submit to our customer support.

We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.

3. Personal information we collect

We collect various personal information regarding you or your device. This includes the following:

  • Information you provide to contact us, specifically email address, first name and last name.

  • Your marketing preferences.

  • Information you share with us in connection with surveys, contests or promotions.

  • Information from your use of our services. This includes: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with our services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

  • Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.

4. How we collect personal information

We obtain personal information from various sources. We do this in three main ways:

  • You provide some of it directly (such as by registering for our app, contacting us through our site, or calling us).

  • We record some of it automatically when you use our services (including with technologies like cookies).

  • We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processor).

5. How we use your personal information

We use the personal information we obtain about you to:

  • Provision of the Services. Create and manage your Account, provide and personalise our services, process payments and respond to your inquiries.

  • Communicating with you. Communicate with you, including by sending you emails about your account and service-related announcements.

  • Surveys and contests. Administer surveys, contests and other promotions.

  • Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Freeze and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your debt solution or what we think may interest you based on other information we hold about you.

  • Advertising. Analyse your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you.

  • Customising the services. Provide you with customised services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.

  • Security. Ensure the security and integrity of our Services.

  • Third party relationships. Manage our vendor and partner relationships.

  • Enforcement. Enforce our Terms of Service and other legal terms and policies.

  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).

  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

  • Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.  

  • Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Freeze Debt account.

  • Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

  • Protecting you and others. To protect your vital interests, or those of others. 

6. How we share your personal information

We share personal information in the following ways:

  • Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyse and improve the services we or they provide.

  • Users.  We share with our Users data regarding usage by End Users of their sites. For example, we provide a User with information about what web page the End User visited before coming to their site and how their End Users interacted with their site. This is so Users can analyse the usage of their sites and improve their services.

  • Business partners.  We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.

  • Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.

  • Process payments. We transmit your personal information via an encrypted connection to our payment processor.  

  • Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Freeze or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.

  • Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

7. Your rights and choices

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

You can access, update, change or delete personal information (or that of your End Users) either directly in your Account or by contacting us at complaints@freezedebt.co.uk to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.

You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:

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

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number

Fax: 01625 524 510
Email: dataprotectionfee@ico.org.uk

Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

Our Cookie Policy explains how you can manage cookies and similar technologies.

8. How we protect your personal information

While no service is completely secure, we have a security measures put in place, keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

9. How we retain your personal information

We retain personal information regarding you or your use of the services for as long as your Account is active or for as long as needed to provide you or our Users with the services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.  

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated and other relevant criteria.

You may delete your Account by contacting us at complaints@freezedebt.co.uk and Freeze will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).

Please note that in the course of providing the services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

10. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

11. How to contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at complaints@freezedebt.co.uk, or write to us at the address below:


SwapGroup LTD.
Attention: Legal - Privacy
2a Hough,
Halifax,
HX3 7AP