1. Who we are and how to contact us
Freedom Global ('we', 'us', 'our') operates the website at freedomglobal.io and the associated Freedom Club member portal. We are an independent currency introducer. We are not authorised or regulated by the Financial Conduct Authority (FCA). We introduce businesses to FCA-authorised and regulated foreign exchange and payment service providers. For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Freedom Global is the data controller in respect of the personal data we collect through this website and our services. Our data protection contact is: [email protected].
2. The personal data we collect
We collect and process the following categories of personal data: (a) Identity data — your name, job title, and company name; (b) Contact data — your business email address and telephone number; (c) Assessment data — your responses to our Smart Discovery questionnaire, including information about your business's currency exposure, transaction volumes, and hedging practices; (d) Account data — your login credentials (password stored as a one-way hash), account preferences, and portal activity; (e) FX Score data — your calculated FX Score, band, category scores, and scoring history; (f) Usage data — pages visited, features used, time spent, and interaction events; (g) Technical data — IP address, browser type and version, device type, operating system, and referring URL; (h) Communications data — the content of enquiries, messages, and correspondence you send us. We do not knowingly collect special category data (such as health, racial or ethnic origin, or political opinions) or data relating to criminal convictions. If you believe you have inadvertently provided such data, please contact us immediately.
3. How we collect your data
We collect personal data directly from you when you: complete our Smart Discovery assessment; register for a Freedom Club account; submit an enquiry via our contact form; correspond with us by email or through the portal messaging system. We also collect data automatically through cookies and similar technologies when you browse our website (see Section 9 on Cookies). We do not purchase personal data from third-party data brokers.
4. How we use your data and our lawful basis
We only process your personal data where we have a lawful basis to do so under UK GDPR Article 6. The table below sets out our processing activities and the lawful basis for each. (a) Responding to your enquiries and providing information about our services — Lawful basis: Legitimate interests (to respond to business enquiries and promote our services). (b) Providing access to the Freedom Club member portal — Lawful basis: Contract (necessary to perform the membership agreement with you). (c) Generating and displaying your FX Score — Lawful basis: Contract (the FX Score is a core deliverable of the Freedom Club membership). (d) Introducing you to FCA-regulated FX and payment providers — Lawful basis: Contract and Legitimate interests (to fulfil our role as an introducer and to match businesses with appropriate providers). (e) Sending market updates, alerts, and briefings through the portal — Lawful basis: Contract (these are features of the Freedom Club membership you have signed up for). (f) Sending direct marketing communications outside the portal — Lawful basis: Consent (we will only send marketing emails where you have opted in). (g) Improving our website and services through usage analytics — Lawful basis: Legitimate interests (to understand how our services are used and to improve them). (h) Maintaining the security of our systems and preventing fraud — Lawful basis: Legitimate interests and Legal obligation. (i) Complying with legal and regulatory obligations — Lawful basis: Legal obligation.
5. Automated decision-making and profiling
Our FX Score is generated by an automated scoring algorithm that processes your assessment responses to produce a numerical score, a band classification, and category scores. This constitutes automated processing within the meaning of UK GDPR Article 22. The FX Score does not produce legal effects or similarly significantly affect you — it is an indicative guide to your business's currency management health and does not determine whether you receive any service, credit, or introduction. You have the right to request human review of your FX Score, to express your point of view, and to contest the result. To do so, please contact us at [email protected].
6. Data sharing and third-party processors
We do not sell your personal data. We may share your data in the following circumstances: (a) FX and payment providers — where you have requested or consented to an introduction, we will share relevant identity and contact data with the provider concerned. We will always inform you before making an introduction. (b) Data processors — we use third-party service providers who process data on our behalf under written data processing agreements. These include our hosting provider (GoDaddy), our authentication service, and our AI briefing provider (OpenAI, where the AI Briefings feature is activated). These processors are contractually bound to process data only on our instructions and to maintain appropriate security measures. (c) Legal and regulatory authorities — we may disclose data where required by law, court order, or regulatory authority. (d) Business transfers — in the event of a merger, acquisition, or sale of assets, personal data may be transferred to the relevant third party, subject to equivalent data protection obligations.
7. International transfers
Our primary infrastructure is hosted within the United Kingdom and European Economic Area. Where we use service providers that process data outside the UK or EEA (for example, OpenAI's servers in the United States), we ensure that appropriate safeguards are in place in accordance with UK GDPR Chapter V. These safeguards include the use of the International Data Transfer Agreement (IDTA) approved by the ICO, or reliance on an adequacy decision where applicable. You may request details of the specific safeguards in place by contacting [email protected].
8. Data retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, having regard to our legal and regulatory obligations. Our retention periods are as follows: (a) Account and portal data — retained for the duration of your Freedom Club membership and for six years thereafter (in line with the Limitation Act 1980 for potential contractual claims); (b) FX Score snapshots — retained for the duration of membership and for three years thereafter; (c) Enquiry and contact form data — retained for three years from the date of the enquiry; (d) Usage and technical data — retained for 13 months on a rolling basis; (e) Financial and transaction-related records — retained for six years in accordance with HMRC guidance. At the end of the applicable retention period, data is securely deleted or anonymised.
9. Cookies
We use cookies and similar technologies on our website. Essential cookies are strictly necessary for the website and portal to function — they maintain your authenticated session and remember your preferences. These cookies are placed on the basis of our legitimate interests in providing a functional service and do not require your consent. We do not currently use analytics, advertising, or tracking cookies that would require your consent under the Privacy and Electronic Communications Regulations (PECR). If we introduce such cookies in the future, we will update this policy and obtain your consent before placing them. You can control and delete cookies through your browser settings, but disabling essential cookies will prevent you from accessing the member portal.
10. Your rights under UK GDPR
Under UK data protection law, you have the following rights in relation to your personal data: (a) Right of access — to request a copy of the personal data we hold about you (Subject Access Request); (b) Right to rectification — to request correction of inaccurate or incomplete data; (c) Right to erasure — to request deletion of your data in certain circumstances ('right to be forgotten'); (d) Right to restrict processing — to request that we limit how we use your data in certain circumstances; (e) Right to data portability — to receive your data in a structured, commonly used, machine-readable format; (f) Right to object — to object to processing based on legitimate interests or for direct marketing purposes; (g) Rights related to automated decision-making — to request human review of automated decisions, including your FX Score (see Section 5); (h) Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please submit a written request to [email protected]. We will respond within one calendar month of receiving your request. We may need to verify your identity before processing your request. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive.
11. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include: encrypted data transmission (TLS/HTTPS) for all website and portal communications; hashed storage of passwords (passwords are never stored in plain text); role-based access controls limiting staff access to personal data on a need-to-know basis; UUID-prefixed document storage with per-organisation isolation; regular security scanning and vulnerability management. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify affected individuals without undue delay.
12. Legitimate interests assessment
Where we rely on legitimate interests as our lawful basis, we have carried out a balancing test to ensure our interests are not overridden by your interests or fundamental rights. Our legitimate interests include: operating and improving our introducer business; responding to business enquiries; maintaining the security of our systems; and preventing fraud. We have assessed that these interests are proportionate and that individuals would reasonably expect their data to be used in these ways. You have the right to object to processing based on legitimate interests at any time by contacting [email protected].
13. Changes to this policy
We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. We will post the updated policy on this page with a revised 'last updated' date. Where changes are material, we will notify registered Freedom Club members by email at least 14 days before the changes take effect. Your continued use of our services after that date constitutes acceptance of the updated policy.
14. Contact us and complaints
If you have any questions, concerns, or requests regarding this privacy policy or our data protection practices, please contact us at: [email protected] or via our contact form at freedomglobal.io/contact. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) — see the note below. We would appreciate the opportunity to address your concerns before you approach the ICO.
You have the right to lodge a complaint with the Information Commissioner's Office (ICO). The ICO is the UK supervisory authority for data protection issues. You can contact the ICO at ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.