Privacy Policy
This Privacy Policy describes how Freedom Factory Inc. (“Freedom Factory,” “we,” “our,” or “us”) may collect, use, and disclose personal information about you. This Privacy Policy applies to information collected when you interact with the “Services,” which include our website located at https://freedomfactory.io and all related components, the PQ1 hardware device, the ethOS software, the Freedom Factory companion application, and such other software applications, products, and services we provide from time to time, including the purchase of Devices through the Services.
Please read this Privacy Policy carefully so that you understand our policies and practices regarding your information. If you do not agree with our policies and practices then your choice is not to interact with the Services. By accessing or using the Services you agree to this Privacy Policy. We encourage you to check this Privacy Policy often so you stay informed about our practices and the choices available to you.
Contents
1. Information We Collect
2. How We Use Your Information
3. Sharing Information
4. Cookies and Similar Technologies
5. Analytics
6. Your Choices
7. Privacy and Blockchains
8. International Transfers
9. Special Notice for EU and UK Residents
10. How We Protect Your Information
11. Information Storage
12. Age Restrictions
13. Changes to this Privacy Policy
14. Third Party Links and Features
15. Contact Us
Information We Collect
Depending on how you interact with the Services, we may collect information about you like:
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Information You Provide. You provide us with information when, for instance, you purchase a Device, register for an event, or communicate with us by email or through community channels.
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Information Collected Automatically. We collect a limited amount of information automatically when you interact with the Services, as described below. We have designed the Services to minimize this collection.
In connection with using or accessing the Services, we may collect the following categories of information.
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Order and Shipping Information. When you purchase a Device, we collect your name, email address, phone number, and shipping address so that we can process, fulfill, and ship your order and provide order confirmations and status updates. Shipping addresses are encrypted in your browser before they are transmitted to us, as described in the How We Protect Your Information section below.
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Commercial Information. Records of the Freedom Factory products you have purchased or considered, such as your order history with us.
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Payment Information. Payments for Devices are processed by third party payment processors, currently including Stripe and Daimo. We do not collect or store your full payment card number or bank account details; your payment information is provided directly to the applicable payment processor, whose use of your information is governed by its own privacy policy.
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Communication and Support Information. Information about communications you submit to us, including through email, Discord, or Telegram, such as your name, contact details, and information about the products and services we have provided to you (for example, device information, serial numbers, and similar identifiers you share with us to obtain repair, warranty, or customer support services).
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Analytics Data. We use self-hosted, cookieless analytics to measure page views, engagement, and conversions on our website. Our analytics receive only limited order details (such as order ID, quantity, and order total) and do not receive names, shipping addresses, email addresses, or payment details. Our servers may also process limited technical information, such as network information, as necessary to deliver the website to your browser and to secure the Services.
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Blockchain Data. If you submit a wallet address to tools we make available (for example, our risk-screening tool), the address may be relayed to public blockchain, naming, and pricing services in order to return results to you; we do not store submitted addresses or link them to customers. Publicly available blockchain data, like wallet addresses and transaction history, is visible to anyone by the nature of public blockchain networks (see the Privacy and Blockchains section below).
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Other Information. Any other information that you choose to provide or that we request.
We may aggregate or de-identify information so that it can no longer identify you, as defined under applicable laws. We may use and/or disclose aggregated or de-identified information for any purpose unless an applicable law says otherwise.
How We Use Your Information
We use the information we collect in connection with what we consider our Everyday Business Activities, which may include using your information to:
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Operate and Provide the Services. We may use the information we collect to provide and operate the Services, like processing your Device orders, sending purchase confirmations, shipping Devices to you, and contacting you about technical notices or security alerts.
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Provide Support, Repairs, and Warranty Services. We may use the information we collect to respond to your inquiries and provide repair, warranty, and customer support services.
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Monitor and Improve the Services. We may use the limited analytics information we collect to analyze the effectiveness of the Services, review use of the Services, and improve the Services.
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Communicate with You about the Services. We may use information we collect about you to communicate with you about the Services, like offers, promotions, and providing other news and information we think will be of interest to you.
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Facilitate a Corporate Transaction. We may use the information we collect during negotiations or in connection with the sale of part or all of our assets, the acquisition of part or all of another business or the business’s assets, or other transaction including but not limited to financing or bankruptcy.
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Foster Safety and Security. We use the information we collect to provide for the safety and security of our users and the Services. This includes detecting and preventing against malicious, deceptive, fraudulent, or illegal activities; improving our security; exercising our legal rights; in compliance with any applicable law; and as permitted by law.
Sharing Information
You should know the ways that we share your information and why we share your information. In connection with our Everyday Business Activities, we may share information collected from or about you in the following circumstances.
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Service Providers. We may share your information with service providers that perform functions or provide services on our behalf, such as payment processors (currently Stripe and Daimo), fulfillment and shipping providers and carriers, email and customer relationship providers, customer support providers, and cloud infrastructure and technical support providers that help us with our business and the Services.
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Comply with Laws and Protect our Rights. We may share your information as we believe to be necessary or appropriate to comply with applicable law and legal processes; respond to requests from public and government authorities including authorities outside your country of residence; protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit the damages that we may sustain.
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Investors and Acquirers. We may transfer your information to advisors, investors, potential transactional partners, or other third parties in connection with the initial actions or engagement of a merger, acquisition, sale of some or all of our stock or assets, change in control, financing, bankruptcy, or similar transaction.
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With Other Third Parties. There are situations when we may disclose your information to third parties beyond our service providers. While we try to control the behavior of our vendors that we understand to be service providers, some of those vendors engage in activities beyond our control.
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With Your Consent or at Your Direction. We may share your information with third parties when you direct us to do so or if you have consented to additional sharing of your information.
We do not sell your personal information, and we do not share your personal information with third parties for cross-context behavioral or targeted advertising.
Cookies and Similar Technologies
Unlike most other online services, we do not use cookies, advertising pixels, browser fingerprinting, or cross-site tracking technologies on our website. Our website analytics are cookieless, as described in the Analytics section below.
Please note that third party sites and services that you may access from the Services operate under their own policies. For example, our hosted checkout is operated by our payment processor on its own website, and embedded video content loads from the applicable third party only after you begin playback. These third parties may use cookies and similar technologies under their own privacy policies, which we encourage you to review. If our use of cookies or similar technologies changes in the future, we will update this Privacy Policy accordingly.
Analytics
We use Matomo, a self-hosted, cookieless analytics platform, to help us understand how visitors use our website, including page views, engagement, clicks, and conversions. Because our Matomo instance is self-hosted, this analytics information is processed on infrastructure we control and is not shared with a third party analytics network. Our analytics receive only limited order details (such as order ID, quantity, and order total) and do not receive names, shipping addresses, email addresses, or payment details. We do not engage third parties to serve advertisements to you across the web, and we do not permit third party advertising networks to collect information about your use of the Services.
Your Choices
You have certain choices about how to protect and limit the collection, use, and sharing of information about you, including:
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Opt-out of Marketing Communications. You may opt-out of receiving marketing communications from us by following the instructions in those communications or by submitting a request to hi@freedomfactory.io. If you opt-out, we may still send you non-promotional communications, such as order confirmations, shipping updates, and messages about our ongoing business relations.
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Access, Correction, and Deletion. You may request that we access, correct, update, or delete personal information we hold about you by emailing us at hi@freedomfactory.io. We will honor such requests to the extent required, and as permitted, by applicable law.
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Do Not Track. Because we do not track our users across websites, we do not respond differently to “Do Not Track” browser settings; the Services do not collect the cross-site browsing information those settings are designed to limit.
Where required by applicable law and depending on your jurisdiction, you may have access to certain additional rights, such as the right to obtain confirmation that we maintain certain personal information relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or block or withdraw consent to the processing of certain personal information (without affecting the lawfulness of processing based on consent before its withdrawal). If you are unable to exercise your rights using the mechanisms above, you may email us at hi@freedomfactory.io. We may ask you to provide us with information, such as your name and email address, necessary to reasonably verify your identity before responding to your request. If we can’t verify your identity, we will not be able to fulfill your request.
Privacy and Blockchains
A key feature of many blockchain technologies, including the Ethereum blockchain network or any other blockchain networks on which the Services rely, is the transparency and public accessibility of on-chain transactions. This includes but is in no way limited to your public sending address (“public key”) and any other information that you choose to include. Additionally, information stored on-chain is public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your public keys may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our Services.
International Transfers
Your personal information may be transferred, processed, and/or stored in countries other than the country in which you are a resident. We are based in the United States, and the information we collect is generally stored in the United States. If you are located outside of the United States, your information is collected in your country and then transferred to the United States—or to another country in which we (or our service providers) operate. For example, in order to fulfill and ship your order, your shipping details may be shared with fulfillment providers and carriers operating in or from the jurisdictions from which we ship Devices, currently the United States, Lithuania, and Hong Kong.
If we transfer personal information originating in the European Economic Area (E.E.A.), the United Kingdom, or Switzerland to a country that has not been recognized as providing an adequate level of data protection, we take steps designed to ensure that the recipient is bound by appropriate safeguards, such as contractual obligations consistent with the E.U. Standard Contractual Clauses together with addenda or language to cover the UK and/or Switzerland, as applicable. In certain situations, the courts, law enforcement agencies, or regulatory authorities in the countries to which your information is transferred might be entitled to access your personal information.
Special Notice for EU and UK Residents
If you are located in the European Economic Area or the United Kingdom, Freedom Factory Inc. is the controller of the personal information described in this Privacy Policy, and this section applies to you.
We only collect, use, or share information about you when we have a valid reason. This is called a “lawful basis.” Specifically, this is one of the following:
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The consent you provide to us at the point of collection of your information;
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The performance of the contract we have with you, such as processing and shipping your Device order;
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The compliance of a legal obligation to which we are subject; or
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The “legitimate interests” of Freedom Factory or a third party, meaning that there are good reasons for the processing of your personal information and that we take measures to minimize the impact on your privacy rights and interests, and that we use your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in gathering and processing personal information, for example, to: (a) ensure that our networks and information are secure; (b) administer and generally conduct business within Freedom Factory; and (c) prevent fraud.
Subject to applicable law, you have the right to: request access to and a copy of the personal information we hold about you; request that we correct inaccurate personal information; request that we erase your personal information; object to or request that we restrict certain processing; receive your personal information in a portable format; withdraw any consent you have provided at any time (without affecting the lawfulness of processing before withdrawal); and lodge a complaint with your local supervisory authority. To exercise these rights, please email us at hi@freedomfactory.io. We try to respond to all legitimate requests within one month.
How We Protect Your Information
We use reasonable procedural, physical, and electronic safeguards to protect your information from unauthorized access or use. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. For example, shipping addresses are encrypted in your browser, using modern public-key cryptography, before they are transmitted to us; our systems store only the encrypted form of your shipping address, and decryption occurs on separate, access-controlled fulfillment systems. However, no method of transmission over the internet or electronic system is completely secure, so we are unable to guarantee absolute security.
The safety and security of your information also depends on you. Never share your seed phrase, recovery phrase, or private cryptographic keys with anyone. Freedom Factory will never ask you for your seed phrase, recovery phrase, or private keys, including in connection with customer support.
Information Storage
We retain your information for as long as necessary to provide the Services, fulfill our legal obligations, enforce our legal agreements, and resolve disputes. In general, we retain personal information for up to five years following your last interaction with us, after which we delete it. The retention periods for particular information may vary on a case-by-case basis depending on the nature of the information, why it was collected, and the applicable legal reason(s) for the retention of your information, and we may retain certain information for longer where necessary to comply with our legal obligations or to protect the safety and security of the Services. Rather than delete your data, we might de-identify it by removing identifying information.
Age Restrictions
The Services are not intended for anyone under the age of 18. We do not knowingly collect or solicit personal information from children. In the event that we encounter information from an individual under the age of 18, we will promptly take steps to delete such information. If you believe your child under the age of 18 has provided information in connection with the Services, please contact us using the information in the Contact Us section below.
Changes to this Privacy Policy
We are always improving the Services, and we create new features regularly. These updates sometimes require us to collect new information or use what we already have differently. Further, the laws regarding personal information and privacy frequently change. We will notify you of any changes we make by revising the date at the top of this page. We may also provide you with a reasonable notice of any material changes before they take effect or as otherwise required by applicable law. If you object to any change, you can stop using the Services. After we post any changes, your continued use of the Services is subject to the updated Privacy Policy.
Third Party Links and Features
The Services may contain links, banners, and/or widgets to third party sites, applications, or services, such as our payment processors’ hosted checkout pages, embedded video content, and community channels like Discord and Telegram. We may also incorporate third party software (including open source software) in the Services. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third party links and features, nor any association with their operators. Freedom Factory is not responsible for the practices of such third parties. Any information you provide to third parties on their sites or services is covered under their privacy and data collection practices and not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.
Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please email us at hi@freedomfactory.io.