Privacy Policy

October 1, 2021.


1. Purpose

dfree® and its affiliates (“dfree® Global Foundation”, “the “dfree® Foundation” or “we”) believe that the responsible use of Personal Data is critical to our business objectives and reputation. This Global Privacy Notice (“Privacy Notice”) explains the different ways in which we collect, use and share Personal Data. The extent and type of information we receive from you depends on the information you provide to us voluntarily. The purpose of this Notice is to ensure that all individuals whose Personally Identifiable Information is collected by dfree® are well informed about how and why dfree® collects Personally Identifiable Information and what rights are available to them, including under the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (‘CCPA’) and any other applicable data protection legislation, hereinafter referred as data protection laws.

2. Scope

This Notice is intended to provide website users, social media users, customers, job applicants, business partners/ vendors and other service providers with information on how dfree® collects, protects and uses Personally Identifiable Information.

If you do not agree with the terms in this privacy policy, do not use the services and sites of dfree®. continued use of the services and sites of dfree® constitutes your freely given, specific and informed consent and agreement to your personal data being processed pursuant to this notice.

3. Definitions

“Data Subject” means an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.

“Pixels” means small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Sites (or other third-party sites) or if an email has been read.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of dfree®.

“We”, “our”, and “us” in this Privacy Notice refers to dfree® Global Foundation, its affiliates and any partners or contractor delivering the services and products herein on behalf of dfree® and its affiliates.

“You” means the individual to whom any given Personal Data covered by this Privacy Policy refers.

4. Collection of Personal Identifiable Information

Authorized Users

dfree®’s websites are not intended for children under the age of 18. If you are under 18 years old, please do not provide information of any kind whatsoever on the Sites. If you are the parent of a child under 18 and believe your child has provided us with personal information, please contact us via Section 15 below and we will remove that information.

Information you actively submit

We collect Personal Information when you voluntarily provide it to us. Any Personal Information we collect is used only to respond to your inquiry, consider your application, process an order or allow you to access specific account information, and is not shared with third parties except as described in this Notice. Personal Information we collect may include contact information, such as your name, address, email address or telephone number, professional information. We may also collect the information you choose to provide to us when requesting information. In the ordinary course of our business, we do not collect or otherwise process Personal Information about race, religion, sexual orientation, health or any other information that is deemed to be sensitive.

Personal Information from other sources

Personal Information may be collected either electronically or physically, including but not limited to emails, cold calls, resumes, social media networking sites, subscription to databases, prospective candidate search engines and online identifiers, sales events, as well as offline events and information provided offline to one of dfree®’s representatives.

Policy statement

dfree® uses commercially reasonable efforts to protect all Personal Data we collect and we do not sell any such data to third parties.

You can visit most of our sites without registering or actively submitting Personal Data to us. If you do not register, general technical user data, including but not limited to, your device’s Internet Protocol (IP) address, operating system and browser type, and the date and time of your visit may be automatically collected through the use of “cookies”, as described below.

Combination & synchronization

We may combine and synchronize information that your device transmits, information that you actively submit and information that we obtain from third party sources (including web publishers, advertisers, data brokers and online service providers that may have obtained information from you or your devices via cookies, pixels, and other tracking technologies for the purpose of analytics and e-commerce).

Information tracking technologies

A technology called cookies may be used to provide you with tailored information. A cookie is a tiny element of data that a website can send to your browser, which may then be stored on your hard drive, so we can recognize you when you return.

If you prefer to not receive cookies while browsing the website, you can set your browser to warn you before accepting them and refuse the cookie(s) when your browser warns you, or you can set your browser to refuse all cookies from the website (or certain parts of the website), and/or you can delete cookies received from the website using your browser, for instance. Cookie handling instructions vary depending on the particular browser being used, and dfree® does not assume responsibility for any undesired results arising from altering your browser’s cookie handling settings.

We may use, and allow third parties to use, pixels (sometimes called web beacons) on our Sites (or other third-party sites). Pixels may be linked to your Personal Information, and they collect the IP address of the device to which the web beacon is sent (for geolocation lookup), the URL of the page the web beacon comes from, the user agent string (for device lookup), and the time it was viewed. dfree® may use a Pixel or cookie to examine what is happening on third-party websites, including programs and sites with marketing and advertising partners, to improve the understanding of site traffic at a granular level and other services provided.

Business information

We do collect Personal Data of our employees, applicants and candidates, business partners, suppliers, and vendors which includes but is not limited to contact names, addresses, phone numbers and email addresses, for the administration of our business relationships. If you feel that your Personal Data or personally identifiable information is being collected inappropriately, please notify us at privacy@dfree®.com.

5. Purpose & use of collected Personal Identifiable Information

Personal Data we collect, and use will depend on the personal information concerned and the specific context in which we collect it and the purpose for which it is used. In general, dfree® uses the data collected for three main purposes, described in detail below.

  1. Sales and Operations: To operate our business including the official website, we use data collected to assess queries, requirements, and process requests for services, to assess website usage and to deliver our services to clients and potential clients.
  2. Communications and Marketing: We use data collected to communicate with you and personalize our communications with you. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from dfree® by email, SMS, post and telephone or other means of communication. We may process your Personal Information to contact you via email, telephone, SMS or other methods of communication to provide you with information regarding our offerings that may be of interest to you.
  3. Careers: We may use the information provided by you in connection with your application for employment to assess your qualifications for employment and we may share this information with clients and affiliates of dfree® solely in connection with our efforts to evaluate you for current and future positions at dfree® and for assignment to one or more dfree® clients.

6. Data protection rights

When we process Personal Data about you, we do so as necessary to provide the website you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of dfree® as described in this Notice.

Below, you will find additional privacy information that you may find important. dfree® adheres to applicable data protection laws including the GDPR in the European Union, as well California CCPA, as referred to below in this Notice, which if applicable, includes the following rights:

  • If the processing of Personal Data is based on your consent, you have a right to withdraw consent at any time for future processing.
  • You have a right to request us to rectify or correct your Personal Data. Please inform us of any data which you would like rectified, and we usually respond within a month of the request.
  • You have a right to access your Personal Data. Please contact us if you would like confirmation that your data is being processed and to request access to your personal data. There is no charge for providing you with this data and it will usually be provided within a month of the request.
  • You have a right to request that your Personal Data be erased, subject to certain exceptions. You may exercise your right to have your personal data erased in a number of circumstances (e.g. if the data is no longer necessary in relation to the purpose for which it was created, or you withdraw your consent). Wherever possible, we will comply with all such requests, though some details are part of dfree®’s permanent records (e.g., your name, accounting records) which cannot reasonably be deleted.
  • You have a right to restrict the processing of your Personal Data. You can tell us that we can keep your data but must stop processing it, including preventing future mailings and communications. If possible, we will inform any third parties to whom your data has been disclosed, of your requirement.
  • You have a right to object to the processing of your Personal Data. We will stop processing your data if you object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority.
  • You have a right to request data portability. Your data is stored across manual records and electronic databases. We will do our best to provide information in a portable format.
  • You have a right not to be subject to automated decision-making including profiling; and
  • You have a right to lodge a complaint with a data protection authority.

Sale of Personal Information

While dfree® does not sell your Personal Information in exchange for any monetary consideration, we do share your information for other purposes, including analysis and e-commerce with third party channels and ad words, that could be deemed a “sale” as defined by the CCPA. We support the CCPA and wish to provide you with control over how your personal information is collected and shared.

7. Information retention & accuracy

We take reasonable steps to ensure that the Personal Information we receive, process, or maintain is accurate, complete, and reliable for its intended use. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the Personal Information collected.

In general, we keep Personal Information only as long as we need it to provide you with the services you requested, to consider your application for current and future positions or for the purpose for which the information was provided. We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us). We may also process data on behalf of third parties who have engaged us. We keep Personal Information processed on behalf of third parties for as long as needed to provide services to the third party in question. However, we reserve the right to retain Personal Information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Data Minimization

We take reasonable steps to ensure that the Personal Information that we process is limited to the purposes set out in this policy or as required to provide you services or access to our services.

9. Sharing of Personal Information and Accountability for Onward Transfer

a) Information associated with your name is shared in accordance with the procedures stated as follows:

  • With your consent.
  • We use affiliated and unaffiliated service providers all over the world that help us deliver our service and run our business subject to confidentiality agreements.
  • We will disclose data as required by law including to meet national security requirements or to protect you, other users, us or third parties from harm, including fraud, data security breaches or where someone’s physical safety seems at risk; and
  • In a reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer accepting the commitments made in this Privacy Policy and in compliance with applicable law.

When dfree® does share your Personal Information with third-party service providers and/or sub-processors, dfree® will:

  • transfer such data only for limited and specified purposes.
  • ascertain that the sub-processor is obligated to provide at least the same level of privacy protection as is required by this Policy.
  • take reasonable and appropriate steps to ensure that the sub-processor effectively processes the Personal Information transferred in a manner consistent with our obligations under this Policy.
  • require the sub-processor to notify dfree® if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by this Policy.
  • upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and
  • provide a summary or a representative copy of the relevant privacy provisions of its contract with that sub-processor to authorized regulators upon request.

b) international transfers and data processing

As a global organization, the Personal Information we collect may be transferred or be accessible internationally throughout dfree®’s offices around the world and between its entities and affiliates. Any transfers throughout dfree®’s offices around the world takes place in accordance with the applicable data privacy laws and in accordance with our internal Privacy and Security Policies.

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.

10. Security of Personal Data

dfree® is committed to protecting the security of your Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure.

11. Protection of Personal Data

dfree® uses reasonable security measures in an effort to prevent loss, misuse and alteration of the information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. We have no control over the security of other sites you might visit, interact with or do business with.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. dfree® may post a notice on the dfree® Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us.

12. Limits to Your Privacy

Our Sites may contain links to external websites and areas where you can provide information to third parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any Personal Information you provide in such areas, and on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third parties before providing them with Personal Information.

13. Choice Regarding Collection, Use & Distribution of Personal Information

You can choose to opt-out whenever your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.

If you choose to opt-out, please contact us via email at privacy@dfree®.com. In such an event, you will be only able to access public areas of the Sites and may be limited in the use of dfree®’s Sites. In certain cases, limiting the use and disclosure of your personal data may impact the functionality or prevent the use of dfree® products or services.

14. Automated Decision-Making

You may be subject to a fully automated decision that could have a legal or negative impact on you if this is necessary to conclude or perform a contract, or if you have granted consent. This automated decision can include profiling in some cases, i.e. the processing of personal data that evaluates resume characteristics.

15. Modifications

We reserve the right to modify this Privacy Notice at any time. If we decide to change our Privacy Notice, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances if any, we disclose it. If we make any material changes, we will notify you by means of a notice on this site. We will use information in accordance with this Privacy Notice under which the information was collected periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information.

16. How to contact us

If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the processing of user information carried out by us, or on our behalf, please contact us by email at info@dfree.com.

dfree®’s privacy statement for California residents

This dfree® Privacy Notice (“Notice”) sets forth dfree® Global Foundation. and its affiliates (“dfree®,” the “Company” or “we”) disclosure obligations under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). California law provides California residents with the right to receive a privacy notice with information about what we have collected, disclosed for business purposes, and sold during the preceding 12 months. This Notice describes the categories of Personal Information we collect, the categories of Personal Information we disclose, the categories of Personal Information sold, if applicable, and a description of Data Subjects rights.

Consumer Rights under the CCPA

Under the CCPA, Data Subjects may have the following consumer rights:

a. Abbreviated Right to Know (Collection): You have the right to request, at no charge, that we disclose to you the categories and specific pieces of Personal Information collected in the prior 12months.

b. Expanded Right to Know (Collection and Disclosure): You have the right to request that we disclose certain information about how we have handled your Personal Information in the prior 12 months, including the:

  • categories of Personal Information collected about you;
  • categories of sources from which we collected your Personal Information;
  • business and/or commercial purposes for collecting and disclosing your Personal Information; and
  • categories of third parties to/with whom your Personal Information has been disclosed/shared, including for a business purpose; and
  • the specific pieces of Personal Information collected about you.

c. Access and Portability: You have the right to obtain a list of categories and a copy of the Personal Information, in a portable and (if technically feasible) readily usable format, collected on you covering the 12-month period preceding the request.

d. Deletion: You have the right to request the deletion of your Personal Information we have collected from you. This right may be subject to certain conditions and limitations under the law.

Right to be Free from Discrimination: dfree® will not discriminate against you for exercising your rights under the CCPA.

Additional Rights under California Law

A business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws. Thank you

    Founded in 2005 by DeForest B. Soaries, Jr., dfree® is a financial freedom movement that addresses the cultural, psychological and spiritual influences on financial wellness and offers practical strategies for achieving financial success.

    EMAIL

    info@dfree.com