Privacy Policy

Effective Date: 20th November 2023

FrescoData LLC and its affiliates (collectively, “Fresco”) respect your privacy. At Fresco, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy outlines how we collect, use, disclose and safeguard your personal data in accordance with global data regulations, including the GDPR and CCPA.

This Privacy policy outlines our practices concerning the collection, utilization and safeguarding of Personal data. We gather various types of Personal data and this notice elucidates the reasons behind such data collection, the entities we may share it with and the stringent measures we implement to uphold data security. Additionally, it clarifies your rights and choices regarding your Personal data as well as how to reach out to us for inquiries concerning our privacy procedures.

It is important to note that we act as representatives for and adhere to the directives of financial institutions, merchants and other partners who function as data controllers. For comprehensive information about how your Personal data is processed in these circumstances, we recommend referring to their respective privacy policies.

Our approach to privacy may differ across the various countries in which we operate, aligning with local norms and legal obligations. Specific privacy notices may be applicable to certain products and services we offer. To gain a deeper understanding of our privacy and information practices pertaining to a particular product or service, we encourage you to visit the dedicated webpage or digital asset associated with it.

1. Information of a Personal Nature That We Might Gather

Any data associated with an individual, whether identified or identifiable, is referred as “Personal Data”. We could potentially gather the following categories of Personal Data:

• Product and Service Data: This covers registration information, along with program-specific data when you directly request our products or services or participate in marketing programs or any affiliated service programs.

• Data from Partners: We may receive data from our trusted partners and service providers. This information may include, but not limited to, your name, contact details and demographic data.

• Online Activity Data: Information about your website, device and mobile app usage, collected through automated means like cookies and similar technologies.

• Employment Application Data: If you apply for a job with us, we may collect information related to your job application and relevant details.

• Business Contact Data: In the case where you represent one of our business partners, we may gather your business contact information.

Personal data that we receive from our Partners

In compliance with applicable data protection regulations, we may obtain specific personal data from our trusted partners, such as third-party service providers, advertisers, business affiliates or publicly available records which may include, but is not limited to, your name, contact details and demographic data. This data is received to facilitate a secure data exchange with customers, with utmost care and confidentiality, ensuring it is utilized to provide enhance services, provide targeted content, prevent fraud, verify identities, improve user experience and for advertising purposes to improve overall user experience. Our partners, as well as ourselves, adhere to this Privacy Policy and comply with relevant data protection laws. The shared data is used exclusively for legitimate business purposes. If required by law, we may process your personal data as a data controller for our own purpose or as a data processor on the instructions of our partners or customers.

Personal data we obtain from Advertisements, Websites and Applications

When you interact with advertisements, websites or applications that are affiliated with our services, we may collect certain personal data about you. This information can include your device type, IP address, browser settings and the pages or content you view. We use various tracking technologies, such as cookies and web beacons, to gather this data. This information helps us understand how you engage with our online ecosystem and allows us to provide you with a more personalized experience. It also assists us in measuring the effectiveness of our advertising campaigns and improving the quality of our services. Rest assured, we handle this data in compliance with relevant privacy laws and regulations and it is used solely for the purposes outlined in this Privacy Policy.

Additionally, when you interact with third-party websites, apps or services that are integrated with ours or feature our content, your personal data may be shared with us by those third parties. This shared information could include details about your interactions, preferences and actions within their platforms. We treat this information with the same care and respect as any data we collect directly. It enables us to offer you a seamless and consistent experience across different digital environments while maintaining a high level of privacy protection. We encourage you to review the privacy policies of these third-party platforms to understand how your data may be used beyond our services.

Personal data we obtain through Job applications

When you apply for a job with our organization, we may collect a range of personal data as part of the application and recruitment process. This information typically includes your name, contact details, resume or curriculum vitae, cover letter, employment history, educational background and any other information you provide as part of your application. We may also collect information such as references, background checks and assessment results during the recruitment process to evaluate your suitability for the position applied for. This data is collected and processed solely for the purpose of assessing your qualifications, contacting you about the job application and facilitating the recruitment process.

Additionally, as part of our commitment to equal opportunity and diversity, we may request demographic information, such as gender, race, or ethnicity, on a voluntary basis. Providing this information is optional and it will not impact your job application. We use this data for internal reporting and to help us ensure that our recruitment practices are fair and inclusive. Your personal data collected during the application process is treated with the utmost confidentiality and is accessible only to those involved in the recruitment and hiring process. If your application is not successful, we may retain your information for a limited period for potential future opportunities, unless you request its deletion. We comply with all applicable data protection laws and regulations in handling your personal data throughout the application and hiring process.

2. How We May Use Your Personal data

At Fresco, we are committed to protecting your privacy and ensuring the responsible use of your personal data. This section of our Privacy Policy outlines the various ways in which we may use the personal data we collect from you:

• Providing and Improving Services: We may use your personal data to deliver, maintain and enhance our products and services. This includes processing transactions, offering customer support and troubleshooting issues.

• Personalization: Your data helps us personalize your experience by tailoring content, recommendations and offers to your preferences and interests.

• Communication: We may use your contact information to communicate with you about updates, promotions, news and important information related to our products and services. You can opt out of these communications at any time.

• Analytics and Research: We analyse your personal data to understand user behaviour, trends and preferences. This data helps us improve our services, develop new features and make informed business decisions.

• Security: Your personal data is crucial for the security and integrity of our systems. We use it to detect and prevent fraud, unauthorized access and other security breaches.

• Customer Support: Your data assists us in providing you with effective customer support, resolving issues and answering your inquiries.

• Recruitment: If you apply for a job with us, your personal data will be used for the recruitment and hiring process.

• Marketing: With your consent, we may use your personal email information for marketing purposes, such as sending promotional emails or showing you targeted advertisements.

• Aggregated and Anonymous Data: We may aggregate and anonymize your personal data to create statistical or research data that cannot be used to identify you. This data may be used for various purposes, including industry analysis and reporting.

• Data Licensing: We may license specific categories of your personal data to our customers for their own commercial purposes, which may include fraud prevention and identity verification services. These customers include, but not limited to, global entities engaged in payment transaction processing, other related payment services, and multinational Fintech and AdTech companies. Your data will be used responsibly and in strict accordance with applicable laws and regulations.

The type of personal data that may be subject to licensing include, but not limited to:

• Demographic information such as occupation, location, age, gender, etc.
• Contact Details such as address, phone and/or email.

Rest assured, this licensing is conducted with a clear focus on safeguarding your information and maintaining the highest standards of data security.

In accordance with relevant legal requirements regarding legal basis for the processing of your personal data, we will utilize your personal data: (i) with your explicit consent; (ii) when processing is necessary for the performance of a contract to which you (the individual) are a party or in order to take steps at your request (the individual) prior to entering into a contract (iii) when a legitimate and paramount interest necessitates the utilization of such information.

We utilize the information we collect for the following purposes. The specific legal basis for processing your information may vary depending on your location and under applicable law, as detailed below.

At Fresco, your privacy and the security of your personal data are of paramount importance to us. This section of our Privacy Policy outlines how we may share your personal data, ensuring transparency and clarity about the ways your data is handled. Please be noted that in below cases your Personal data may be shared with us by or we may share this information with. Please take a moment to review this information carefully.:

• We will share your personal data when you have provided clear and voluntary consent for specific purposes. This might include sharing data with trusted third parties for marketing promotions or partner offers. You have the right to withdraw your consent at any time.

• To provide you with our services, we collaborate with trusted service providers who process your data on our behalf. These partners may include payment processors, delivery companies or IT service providers. Rest assured that we select service providers who adhere to rigorous data protection standards.

• We may disclose your personal data when required by applicable laws, regulations or legal processes. This includes sharing data with law enforcement agencies, government authorities or regulatory bodies when necessary.

• We may share your data with our trusted business partners for joint marketing initiatives, collaborations or co-branded services. These partnerships are designed to enhance your experience and provide you with valuable offers and opportunities.

• We may share your data with our trusted customers through licensing agreements, enabling them to use your data to enhance their services. These agreements strictly adhere to stringent data protection regulations.

• If there is a merger, acquisition or any other type of corporate transaction involving Fresco, your personal data may be transferred as part of the business assets. Rest assured that your data will continue to be protected following any such transaction.

• We may share your personal data when it is necessary to protect our legal rights, property or safety, as well as the rights, property and safety of our customers, partners, and employees. This includes sharing information to prevent fraud or address security issues.

• We may share anonymized and aggregated data that cannot be used to identify individuals. This information is often used for research, analytics and industry insights, benefiting both our company and the broader community.

• If you are located outside the country where Fresco is based, please note we may act as data agent that participates in transferring your personal data internationally. We take appropriate measures to ensure that your data remains secure and protected in accordance with applicable data protection laws.

We want you to have control over your personal data. If you have questions or concerns about how we share your data, please get in touch with our privacy team using our “Contact Us” section.

4. Data Subject Rights

Fresco is dedicated to respecting your privacy and providing you with choices and control over your personal data. Please take a moment to familiarize yourself with your rights and options:

• Data Access: You have the right to request access to the personal data we hold about you. This allows you to verify what data we have collected and how we use it.

• Data Correction: If you believe that any of the personal data we hold about you is inaccurate or incomplete, you can request corrections or updates. We encourage you to keep your information accurate and up-to-date.

• Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used and machine-readable format. This allows you to transfer your data to another organization if you wish.

• Data Restriction: Under certain circumstances, you can request the restriction of processing your personal data. This means we will temporarily suspend the use of your data while we investigate your request.

• Data Objection: You can object to the processing of your personal data for specific purpose, such as direct marketing. We will respect your request unless we have a legitimate reason to continue processing your data.

• Consent Withdrawal: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

• Data Erasure: You have the right to request the deletion of your personal data. This includes instances where your data is no longer necessary for the purposes for which it was collected.

• Marketing Control: You can manage your marketing preferences and opt-out of receiving promotional communications from us at any time. Instructions for unsubscribing are typically provided in marketing emails.

• Browsing Control: You have the option to control cookies and tracking technologies through your browser settings or by using our website’s cookie preference tools. Please review our Cookie Policy for more information.

• Do Not Track: Your web browser may offer a “Do Not Track” option. While our website respects these signals, please note that we may still collect and use information for essential purposes.

• Privacy Concerns: If you believe your privacy rights have been violated or you have concerns about how your data is handled, please contact us using our “Contact Us” section. We take privacy complaints seriously and will investigate and address them accordingly.

• Right to Complaint: In accordance with your country or local regulations, you are entitled to file a complaint regarding the utilization of your personal data with the appropriate supervisory authority or regulatory body.

Depending on your country and the applicable law you or a party authorized to act on your behalf, can exercise your rights or choices to control your personal data by submitting a request in our “Contact Us” or by writing to us at the following address:

FrescoData LLC

Legal Department

5838 Edison Pl Suite 210

Carlsbad CA 92008, USA

We will not refuse or impose varying charges if you decide to exercise these rights.

Time Limits for Responding to Data Protection Rights Requests:

We are committed to respecting and protecting your data privacy rights. If you choose to exercise your data protection rights, including but not limited to the right to access, rectify, erase or object to the processing of your personal data, please note that we will make every effort to respond to your request promptly. In accordance with applicable data protection laws, our standard response time for addressing data protection rights requests is one calendar month from the date of receiving a valid request. However, in certain circumstances, this period may be extended in accordance with the law. If an extension is necessary, we will notify you within one month of receiving your request, explaining the reasons for the delay. Rest assured that we will handle all requests with the utmost diligence and in compliance with relevant data protection regulations.

 

5. Transferring Data

FrescoData is a global data expert and consultant. As part of our services, it may be necessary for us to transfer your data to various locations or customers or third parties.  The data protections laws vary for every country and may be different as the country from which you initially provided the information. In accordance with this Privacy policy, we comply with the applicable legal requirements when transferring Personal data to other countries. This section of our Privacy policy explains how we transfer your personal data and the steps we take to ensure the security of these transfers.

• International Data Transfers: Your personal data may be transferred, processed or stored in countries outside the European Economic Area (EEA), United States or your home jurisdiction, where different data protection laws may apply. We take every measure to ensure your personal data remains secure and protected, regardless of the destination.

• Legal Bases for Data Transfers: We commit to transferring your personal data only when there’s a valid legal basis and legitimate purpose. These may include:

• Consent: Your explicit consent for the data transfer.
• Contractual Necessity: When the transfer is essential for fulfilling a contract.
• Legal Compliance: Transfers required to meet legal obligations or respond to lawful government requests.
• Legitimate Interests: Transfers that serve our legitimate interests, provided they do not infringe on your rights and freedoms.

• Safeguarding Your Data During Transfers: To protect your personal data during international transfers, we employ robust security measures such as:

• Data Security: Implementing technical and organizational safeguards to prevent unauthorized access, disclosure, alteration or destruction of your data.
• Data Transfer Mechanisms: Utilizing GDPR-approved mechanisms, like Standard Contractual Clauses or other authorized methods to safeguard data transfers.
• Data Minimization: Only transferring the minimum amount of data required for the intended purpose.
• Data Transfer Mechanism: To facilitate the lawful and secure transfer of your personal data to recipients in countries outside the European Economic Area (EEA) or other regions with data protection regulations, we may utilize specific data transfer mechanisms recognized by data protection authorities. These mechanisms include Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs) or other legal mechanisms as required by the applicable data protection laws. These mechanisms serve to safeguard your data and maintain the high standards of data protection to which we are committed.

• Sharing Data with Third Parties: We may share your personal data with trusted third-party service providers, partners or affiliates who are bound by contractual agreements to adhere to data protection standards in compliance with GDPR, CCPA or relevant regulations.

• Data Subject Rights: If your data is transferred internationally, you may have specific rights related to the protection of your personal data. To understand and exercise these rights, please contact us using the “Contact Us” page.

• Changes to Data Transfer Practices: Our data transfer practices are subject to change due to evolving legal requirements or business operations. We will update this Privacy Policy accordingly. We recommend checking this section regularly for the latest information.

• Data Protection Impact Assessment (DPIA): If required by the applicable data protection laws, we may ask Data Processor to conduct a Data Protection Impact Assessment to evaluate and mitigate the potential risks associated with the transfer of your personal data.

At Fresco, we take data transfers seriously and are committed to upholding the privacy and security of your personal data in compliance with GDPR, CCPA and applicable laws. If you have questions or concerns about our data transfer practices, please reach out to us from “Contact Us” section. Your privacy is our priority and we are dedicated to ensuring your data is handled with care and in line with data protection regulations.

6. Safeguarding of Your Personal Data

At Fresco, safeguarding your personal data is a top priority. We are committed to ensuring the security and confidentiality of the data you entrust to us. This section of our Privacy Policy explains the measures we have in place to protect your personal data effectively.

• We utilize advanced encryption technologies to secure your personal data during transmission. This means that any data exchanged between your device and our servers remains encrypted and unreadable to unauthorized parties. You can recognize secure connections by looking for “https” in the website address and a padlock icon in your browser.

• Your personal data in our possession is maintained under strict controls. Our data storage systems are designed to protect against unauthorized access, data breaches and other security threats. We regularly review and update our security protocols to stay ahead of emerging risks.

• Access to your personal data is restricted to authorized personnel who require this information to perform their job duties. We implement role-based access controls and conduct regular training to ensure that our employees understand the importance of data security and privacy.

• We conduct security audits and assessments of our systems and infrastructure to identify and rectify vulnerabilities promptly. This ongoing process helps us maintain a high level of security and protect your personal data from potential threats.

• We are committed to complying with all relevant data protection laws and regulations. This includes adherence to the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), if applicable. We maintain a thorough understanding of these laws and continuously update our practices to align with changing requirements.

• When we engage third-party service providers, partners or vendors, we ensure that they meet our stringent security and privacy standards. All such parties are contractually bound to uphold data protection requirements.

• Despite our best efforts, no system is entirely immune to potential security incidents. In the unlikely event of a data breach or security compromise, we have a well-defined incident response plan in place. We will promptly investigate and take appropriate action to mitigate any impact on your personal data.

• We encourage you to use strong, unique passwords for your accounts regularly update your login credentials, and be cautious of phishing attempts and suspicious emails. If you ever suspect any unauthorized activity related to your account, please report it to us immediately.

7. For how long your personal data is retained

Fresco or its affiliates (“we”) may retain the personal data we collect or supply where we have an ongoing legitimate business need to do so. In certain circumstances, we may need to keep your information for legal reasons after our contractual relationship has ended for example, situations where we are made subject to a legal obligation, where we require access to your information to effectively resolve requests or complaints, as evidence to compliance laws, in connection to litigation or regulatory matters or conclusion of your recruitment process. Once there is no valid business necessity or legal requirement for retaining your personal data, we will either delete or anonymize it. In cases where deletion or anonymization is not immediately feasible, the data is securely archived and is isolated from any further processing until deletion becomes viable. Archived data will have a maximum retention period of 8 years. A detailed retention schedules are provided in below table for reference.

Fresco or its affiliates (“we”) may retain the personal data we collect or supply where we have an ongoing legitimate business need to do so. In certain circumstances, we may need to keep your information for legal reasons after our contractual relationship has ended, for example, situations where we are made subject to a legal obligation, where we require access to your information to effectively resolve requests or complaints, as evidence to compliance laws, in connection to litigation or regulatory matters or conclusion of your recruitment process. Once there is no valid business necessity or legal requirement for retaining your data, we will delete or anonymize it. In cases where deletion or anonymization is not immediately feasible, the data is securely archived and isolated from any further processing until deletion becomes viable. Archived data will have a maximum retention period of 8 years. Detailed retention schedules are provided in the below table for reference.

Privacy Policy Review and Updates

This policy will undergo an annual review to ensure that it reflects any changes in our privacy practices. Additionally, periodic revisions may occur as needed to incorporate any alterations.

How to Contact Us

You may submit a request to exercise your rights to your Personal Data on our “Contact Us” page or by emailing us at legal@frescodata.com. If you have any questions, comments, or complaints about our privacy practices, please email us at legal@frescodata.com or write to us at:

FrescoData LLC
Legal Department
5838 Edison Pl Suite 210
Carlsbad CA 92008, USA

To learn more about how we safeguard your data in our Email Marketing efforts, please read our Email Marketing Privacy Policy by clicking here.