Data Privacy Policy

1.   Preamble

First of all, thank you for choosing Freely services!

In this document, you will find all the important information about your personal data protection. Within the use of our website www.freelyapp.cz and our mobile application Freely (hereinafter as “Freely”) are we, company FreeDrinks s.r.o., with its registered office at Lípová 512/22, 120 00 Prague 2, ID No.: 074 22 164, registered in the Commercial Register administered by the Municipal Court in Prague, File No.: C 300788, controller of your personal data (hereinafter as “We” or “Controller”).

2.   How do we collect your personal data?

Your personal data are collected:

(i) Within the registration to Freely:

If you download and open our mobile application Freely, you will be able to register to Freely. We need your registration to create your personal account. Within the registration we collect for example your e-mail address, name, surname and date of birth.

(ii) While using Freely:

You can use Freely immediately after a successful registration. While using Freely we have the right to collect your personal data related to your usage of Freely. We collect for example the data about all the drinks you have chosen while using Freely.

(iii) When you fill in the contact form on the website www.freelyapp.cz:

If you fill in the contact form on our website, you agree that we, as the controller of your personal data, will collect your name, e-mail address and phone number. However, the only necessary data to contact us is your e-mail address. We need to collect this personal data so that we are able to response to your message.

(iv) When you register a new business or venue to Freely:

In this case, we need to collect personal data to register the business or venue to Freely. Within this registration we collect: name of the business, name, surname and e-mail address of the contact person.

You can find more information about the usage of Freely in the General Terms and Conditions available on the website www.freelyapp.cz (“Terms and Conditions”).

3.   Which personal data do we collect?

In the text below you find all the important information about the personal data we collect.

(i) Personal data collected during the registration to Freely:

This category includes your personal data collected during the registration to Freely and while using Freely. Accepting this Privacy Policy document, you agree that we may collect your: e-mail address, name and surname, date of birth, sex and nationality. We need this data to create you an account to use Freely (this category hereinafter as “Personal data collected within registration”).

(ii) Personal data collected while using Freely:

This category contains all the personal data we collect while using Freely:

-       information about the type of your account, whether you have a membership or not (“Subscription”);

-       information related to your usage of Freely. This contains date and time of using coupons for drinks, including your rating (closely described in the Terms and Conditions). We might also collect the data from adverts and information about your usage of third-parties applications;

-       technical data including the information about URL address, IP address, cookies, type of the device used to access Freely, type of network connection (for example WiFi, 3G, LTE) and provider, type of the browser, language used for the administration of the digital rights, operating system and the version of Freely mobile application. Find more information about the technical data under article Cookies (this category hereinafter as “Personal data collected while using Freely”).

(iii) Other personal data collected with your previous consent:

In this category, you find all the personal data we collect with your previous agreement. This data enables us to provide you other important functions to use Freely.

-       additional mobile data, which we are able to collect after your previous consent: exact position of your mobile device. This enables us to use GPS and provide you with functions such as the list of the closest venues and other related functions;

-       payment information. These data are collected only after creating a membership and are processed by the company GoPay s.r.o. (closely described in Terms and Conditions). These data are: type of a credit card, date of expiration and CVV code;

-       personal data provided within competition, exploration and lotteries. These data are collected only if you participate in such a competition;

-       personal data collected for marketing purposes. These data enable us to send you a marketing communication through Freely, e-mail address or third party (this category hereinafter as “Other personal data collected with previous consent”).

4.   Cookies

We use cookies to administrate Freely services. Cookies is a small amount of data, which is saved in your computer or other device. Usage of cookies enables us to detect if you have already visited Freely website from your device and simplify your login and orientation on the website. These data are used to increase your comfort while using Freely. You can easily deactivate it within your internet browser.

5.   For what purpose do we collect your personal data?

In this article, you will find the reasons to use your personal data and what is the legal basis.

(i) Purpose: To provide you with Freely services, adapt it to your usage, provide you with suggestions, new functions and advertising.

-     legal basis: legitimate interests and fulfillment of the usage contract

-     category of personal data: Personal data collected within registration

(ii) Purpose: To be able to communicate with you in connection to Freely

-     legal basis: legitimate interests and fulfillment of the usage contract

-     category of personal data: Personal data collected within registration

(iii) Purpose: To activate your Subscription and process your payment

-     legal basis: Fulfillment of the usage contract, legitimate interests, agreement

-     category of personal data: Other personal data collected with previous consent

(iv) Purpose: To be able to communicate with you via e-mail and notifications, for a purpose of marketing, research, participation in competitions and promotion

-     legal basis: Agreement

-     category of personal data: Personal data collected within registration, Other personal data collected with previous consent – specifically personal data for the purpose of marketing and competitions

(v) Purpose: To provide you with specific functions and to view a location-based content

-     legal basis: Agreement

-     category of personal data: Other personal data collected with previous consent, specifically additional mobile data

6.   Personal data sharing

In this article, you find a list of situations, when we are able to share your personal data. Without your previous agreement, we do not make any of your personal data publicly available. If you decide to use one of our functions, where is sharing of your personal data necessary for proper use of Freely, or you give a consent, we have the right to share some of your personal data with these recipients:

·         Third party applications – if you login or connect to a third party application (for example social network), your personal data might be shared with this third party application;

Below are listed the recipients, with whom we may share your personal data (closely described in the article 3):

·         Service providers and others – To provide you with a correct functionality of Freely, we use some of the other service providers. These providers are: service providers that save and administrate the mobile and web application Freely and marketing and advertising providers.

·         Business partners – To provide you with Freely services, we need to share some of your personal data with our partner venues. These partners are offering you free drinks (as described in Terms and Conditions) and are available on the website www.freelyapp.cz. We share only age of the user (not the specific date of birth), sex and time of using Freely.

·         Authorities – Your personal data will be shared due to relevant laws, within legal processes or when it is necessary for our own legitimate interests or legitimate interests of third parties related to national security, law enforcement, litigation, criminal investigations, security protection of every person or to prevent death or immediate health damage, assuming that this interest is not according to our opinion outweighed by your interest within the fundamental rights and freedoms requiring a personal data protection.

7.   How long can we store your personal data?

Your personal data will be processed for the period of time we provide you with Freely services, or for the time necessary to fulfill the archiving obligation according to the applicable law. Your personal data will be kept for the time necessary to exercise the rights and obligations arising from the contractual relationship between you and the Controller (as stated in the Preamble of this document) and the exercise of claims arising from these contractual relationships (for 15 years from the termination of the contractual relationship). The data will be also retained for as long as the consent to the processing of personal data for marketing purposes is revoked, but no longer than 3 years if the personal data is processed by consent. You can revoke your consent at any time, for example by sending an email to info@freelyapp.cz.

8.   Your rights

In this article, you find all your rights arising from the new regulation of the European parliament and of the Council (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter “GDPR”):

·         the right of access to your personal data (article 15 of the GDPR);

·         the right to repair your personal data (article 16 of the GDPR), or the restriction of processing;

·         the right to delete your personal data (article 17 of the GDPR);

·         the right to object to processing (article 21 of the GDPR);

·         the right to data portability (article 20 of the GDPR);

·         the right to withdraw consent to the processing of personal data in writing or electronically to the address or email of the controller listed in article 7 of this Data Privacy Policy;

·         the right not to be the subject of a decision based solely on automatic decision making, including profiling, if the decision has legal effect on you or has a similarly significant effect; and

·         the right to file a complaint with the Personal Data Protection Office if you believe that your right to privacy has been compromised.

9.   Protection of your personal data

We do our best to protect your privacy and your personal data. Therefore, we hereby declare, that we, the company FreeDrinks s.r.o. as a controller of your personal data, have taken all appropriate technical and organizational measures to protect your personal data, data repositories and personal data repositories. We also declare, that personal data can only be accessed by authorized persons. In this context, we would also like to inform you that we may display third-party ads and other content referring to third-party sites, and we are not responsible for this content or have any control over it.

10.  Age limit

Freely is focused primarily on providing coupons for alcoholic beverages offered by our business partners. In this context, Freely is not intended for persons under 18 years of age. If you do not meet this age limit, please do not use Freely and do not tell us any of your personal data.

11.  Potential changes of Data Privacy Policy

We reserve the right to make changes to this Data Privacy Policy. In the event of such a change, we will notify you either through Freely or via e-mail.

12.  Contact

FreeDrinks s.r.o.

Lípová 512/22

Nové Město

120 00 Prague 2

Czech Republic

info@freelyapp.cz

© FreeDrinks s.r.o.