Privacy Policy

Freeus, LLC (“Freeus”) collects data to operate effectively and provide its core service offerings. Below, you will find a list of our products, services, and processes that gather personal data, our purpose and legal basis for processing that information, who we share that information with, and how long we hold that information.

Description of Product, Service, or Process

Orion is a service that stores information from device users on behalf of dealers.

Categories of Personal Data 

- Personal Identifiers
 - Protected Class Information
 - Commercial Information
 - Internet Data
 - Geolocation Data

Category of Data Subjects

Orion gathers data from device users. The Orion web portal service gathers information from dealers who use the web portal. 

Purpose of Processing

Orion gathers this information for billing device users, emergency response, determining a device user's location, and recording devices purchased by dealers from Freeus. 

Business Purpose(s) for Using Personal Information

- Performing services on behalf of the business or service provider including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing financing; providing advertising or marketing services; providing analytic services; or providing similar services on behalf of the business or service provider.

Commercial Purpose for Using Personal Information

Not applicable. 

Legal Basis for Processing

- There is a legitimate business interest in handling the information.
 - Handling the personal information is protecting the person's vital interest (or a third-party's vital interest).

Sources from Which Freeus Collected Information

This information is gathered from dealers and device users. 

Categories of third Parties to Whom Freeus Sold Personal Information

Information is not sold.

Categories of third Parties with Whom Freeus Disclosed Personal Information for a Business Purpose

Orion provides geographic location data to geolocation service providers who can accurately determine a device user's location. 

Orion provides device ID to organizations to cellular organizations to register devices on a cellular network.

Orion provides information to SMS service providers.  

Automated Processing or Profiling

Automated processing occurs.

If Automated Processing is Used, Please Describe what the Automated Processing Does

The Orion system utilizes some automated processing to determine a device user's geographical location. 

Describe What Decisions, if any, Result from the Automated Processing

This information is gathered automatically to dispatch emergency services to a device user during an emergency.  

Whether the Personal Data is Transferred Internationally

This information is processed in the United States. 

Retention Period

Personal information, address information, and IP address is retained until the device user ends the use of the device. 

A history of purchased products and services, MAC address, a device user's name is held in perpetuity. 

Cookie browsing data from the Orion portal is deleted when a browsing session times out or after 12 hours. 

Device numbers are deleted when a device is decommissioned. 


 


Description of Product, Service, or Process

Freeus IOT Platform is an in-house application that allows dealers and customer to provide information for the use of devices. 

Categories of Personal Data 

- Personal Identifiers
 - Internet Data
 - Geolocation Data

Category of Data Subjects

Freeus IOT Platform gathers information from device users and dealers who sell devices to users. 

Purpose of Processing

Freeus IOT Platform gathers this information to setup user accounts, register devices to users, and to track a user's location in the event of an incident where a device is activated. 

Business Purpose(s) for Using Personal Information

- Performing services on behalf of the business or service provider including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing financing; providing advertising or marketing services; providing analytic services; or providing similar services on behalf of the business or service provider.

Commercial Purpose for Using Personal Information

Not applicable. 

Legal Basis for Processing

- Handling the personal information is protecting the person's vital interest (or a third-party's vital interest).
 - There is a legitimate business interest in handling the information.

Sources from Which Freeus Collected Information

This information is gathered directly from the device user, a dealer, or-for geolocation data-the device. 

Categories of third Parties to Whom Freeus Sold Personal Information

Information is not sold.

Categories of third Parties with Whom Freeus Disclosed Personal Information for a Business Purpose

Freeus IOT Platform share geolocation data and device name with geolocation services. 

Automated Processing or Profiling

Automated processing does not occur.

Whether the Personal Data is Transferred Internationally

This information is processed in the United States. 

Retention Period

This information is kept in perpetuity. 

Description of Product, Service, or Process

Employment, Onboarding, and HR Management

Categories of Personal Data 

- Personal Identifiers
 - Commercial Information

Category of Data Subjects

Freeus gathers this information from its employees. 

Purpose of Processing

Freeus gathers this information to enter into, and manage, the employment relationship with its prospective and current employees. For example, Freeus gathers this information for background checks, benefits, accounting, and expense reimbursement. 

Business Purpose(s) for Using Personal Information

- Performing services on behalf of the business or service provider including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; providing financing; providing advertising or marketing services; providing analytic services; or providing similar services on behalf of the business or service provider.

Commercial Purpose for Using Personal Information

Not applicable. 

Legal Basis for Processing

- There is a legal obligation to handle the personal information.
 - Personal information is handled under contract.

Sources from Which Freeus Collected Information

Freeus gathers this information directly from its employees. 

Categories of third Parties to Whom Freeus Sold Personal Information

Information is not sold.

Categories of third Parties with Whom Freeus Disclosed Personal Information for a Business Purpose

Freeus provides this information to payroll and benefits administrators, business management software, and accounting software. 

Automated Processing or Profiling

Automated processing does not occur.

Whether the Personal Data is Transferred Internationally

This information is processed in the United States. 

Retention Period

For the duration of employment and in some cases indefinitely to comply with labor and employment laws. 

Your rights with regard to the data we collect:

You may ask Freeus to access, rectify, erase, and restrict how we process your Personal Data. You may review the Personal Data we have in our Information and Communications systems concerning you and make corrections to that Personal Data.  In certain circumstances, you may even ask that we delete some of the Personal Data we may have collected about you or restrict how we process that information. 

We will endeavor to respond to your requests within 30 days. Should we be unable to comply within 30 days, we will contact you and let you know of any delay.

Exercising Your Rights:

If you want to exercise your rights, you may contact us or our data protection office at:

Organization

Privacy Point of Contact

Freeus
 Address: P.O. Box 151064
 Ogden, UT 84415
 Phone: 888-924-1026
 Email: privacy@freeus.com

Privacy Department
 
 Email: privacy@freeus.com

Freeus will not discriminate against you because you have made a request to exercise your privacy rights.

The Privacy Point of Contact listed above, as well as employees who work with the Privacy Point of Contact, have received training to help you exercise your privacy rights.

Contacting Supervisory Authorities:

If you would like to lodge a complaint against us, you may contact your local supervisory authority. If you have trouble locating a supervisory authority, please contact Privacy Department above and they will help you contact a supervisory authority. 

Changes to our privacy statement:

We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement may also be obtained by contacting the Privacy Department at the information above and requesting a paper copy.

This privacy statement was last updated on 04-30-2020.