Privacy Policy

Last updated: March 12, 2025

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how FreshOS LLC (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, the United Kingdom General Data Protection Regulation, and the General Data Protection Regulation which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SITE. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.

1. Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

  • Identifiers – A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and account name.

  • Customer Records Information – Name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information.

  • Internet or Other Electronic Network Activity Information – Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

  • Professional or Employment-Related Information – Place of employment, position, job history, salary, resume, and other related data.

This personal information is required to provide our services to you. If you do not provide the requested personal information, it may delay or prevent us from providing our services.

2. Cookies and Other Tracking Technologies

Cookies

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site uses:

  • Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.

  • Performance and Functionality – These cookies enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences, such as language and geographic location. These cookies are nonessential to the use of our Site, but without them, certain functionality may become unavailable. A mix of first-party and third-party cookies are used.

  • Advertising – These cookies make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and, in some cases, select advertisements based on your interests. FreshOS sometimes shares online data collected through these cookies with advertising partners. This means that when you visit another site, you may see ads based on your browsing patterns on our Site.

  • Analytics and Customization – FreshOS uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate, and continually improve the Site. For example, we use Google Analytics on the Site to collect page URL/page title and user browser/system information, which includes browser type, referrer, language, Java/Flash support, IP address, and ad-serving data. To learn more about how Google Analytics collects and processes data, visit Google’s Privacy Policy. To opt-out of Google Analytics, visit Google's opt-out page.

  • Social Media – These cookies connect our Site to third-party social media platforms. For example, they enable you to share our Site’s content through social networks and other websites. They also remember your details after you sign in to a social media account from a website. These cookies may also be used for advertising purposes.

  • Unclassified – These cookies have not yet been categorized. We are in the process of classifying them with the help of their providers.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs), which are used along with cookies to compile aggregated statistics to analyze how our Site is used. Web beacons may also be used in some of our emails to track which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

We use third parties to gather information about how you and others use our Site. For example, we track how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

Targeted Advertising

Targeted Advertising (also known as online behavioral advertising) uses information collected on an individual’s web browsing behavior, such as the pages they have visited or the searches they have made. Third parties collect this information by placing or accessing cookies in your browser when you visit this Site or other websites.

To learn more about third-party advertisers that may be aware of your visit to our Site and to understand your choices about turning off such advertisers’ cookies, visit:

How to Manage Cookies

You have the right to decide whether to accept or reject certain cookies. You can set your browser to not accept cookies, and the above websites provide instructions on how to remove cookies from your browser. However, some of our Site features may not function properly if cookies are disabled. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

3. Do Not Track and Global Privacy Control

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT")feature or Global Privacy Control (GPC) setting that you can activate to signal your privacy preference not to have data about your online browsing activities sold or shared.

At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals.

However, we respect the GPC signal. If you have enabled the GPC setting in your browser, we will not sell or share your personal information with third parties.

4. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions, or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see below “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for it separately and clearly.

Opting Out of Promotional Communications

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us using one of the methods listed in the "How to Contact Us" section below; or

  • Using the “unsubscribe” link in emails or replying "STOP" to texts.

We may ask you to confirm or update your marketing preferences if you request further services from us in the future or if there are changes in the law, regulation, or the structure of our business.

5. How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text, email, or through our Site. However, we may also collect information:

  • From publicly accessible sources

  • Directly from a third party

  • From cookies on our Site

  • Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks, connections, communications systems, email, and instant messaging systems

6. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, such as:

  • To comply with our legal and regulatory obligations;

  • For the performance of our contract with you or to take steps at your request before entering into a contract;

  • For our legitimate interests or those of a third party; or

  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

FreshOS collects and processes personal information for various business and legal purposes. We use your information to provide our services to you, ensuring the performance of our contract or taking necessary steps before entering into a contract. We also use it to prevent and detect fraud against you or FreshOS, which serves our legitimate interest in minimizing fraudulent activities that could harm both parties. Additionally, we process personal information to comply with professional, legal, and regulatory obligations applicable to our business.

To maintain operational efficiency and service quality, we use your information for training, improving our processes, and adhering to business policies, including security and internet use. This helps us follow internal procedures and deliver the best possible service. We also ensure the confidentiality of commercially sensitive information to protect trade secrets and other valuable data. Furthermore, statistical analysis of financial performance, customer base, and service usage helps us manage our business effectively and detect potential criminal activities.

FreshOS updates and enhances customer records to maintain accuracy and compliance with legal requirements, as well as to keep in touch with customers about orders and new services. We also use personal information for marketing purposes, reaching out to existing and former customers, third parties who have shown interest in our services, and potential new clients. This allows us to promote our business while respecting legal guidelines and individual preferences.

Additionally, we may anonymize, aggregate, or de-identify personal information to analyze industry trends, conduct validation studies, compile reports, and improve our services. Since this data does not identify individuals, we may use it for any purpose.

7. Who We Share Your Personal Information With

We routinely share personal information with:

  • Our Affiliates and Subsidiaries. We disclose your personal information to our affiliates and subsidiaries to fulfill any purpose described in this Privacy Policy.

  • Our Business Partners. We disclose your personal information to other companies with whom we partner to provide the Site and our services, promote our services or other promotions to our customers, and carry out other activities described in this Privacy Policy.

  • Our Service Providers. We disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf.

  • Our Analytics Providers. We disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Site, marketing, and advertising efforts.

  • Our Marketing and Advertising Partners. We disclose your personal information to our marketing and advertising partners, including social media networks, third-party advertising networks, and other parties that assist us in serving, measuring the performance of, and optimizing our advertisements.

  • Governmental and Public Authorities. We disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.

  • Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may also need to share some personal information with other parties if we believe it is necessary or appropriate to:

  1. Protect our operations and those of our affiliates and subsidiaries.

  2. Investigate and prevent fraud and other illegal activity.

  3. Protect our rights, privacy, safety, property, and/or those of others.

  4. Pursue available remedies or limit damages that we may sustain.

We may disclose your personal information for other reasons described at the time of collection or prior to disclosing your information. Additionally, we may disclose your personal information with your consent or when you direct us to do so.

Except as set forth above, we will not share your personal information with any other third party.

8. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing our services to you. After that, we will keep your personal information only as long as necessary to:

  • Respond to any questions, complaints, or claims made by you or on your behalf.

  • Show that we treated you fairly.

  • Improve our security or detect and prevent fraud.

  • Comply with legal or regulatory obligations or keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of personal information, the potential risk from unauthorized use or disclosure, the purposes for which we use the information, whether we can achieve the purposes through other means, and applicable legal requirements.

9. Children and Our Site

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself, including, but not limited to, your name, address, email address, or any screen name or username you may use.

If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have information from or about a child under 13, please refer to the "How to Contact Us" section below.

For tips on protecting children's privacy online, please visit the FTC’s website at www.ftc.gov.

10. Keeping Your Personal Information Secure

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, alteration, or disclosure.

However, the transmission of information via the Internet is never completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service.

11. Where Your Personal Information is Held

Information may be held at our offices and those of our third-party agencies, service providers, representatives, and agents as described above (see "Who We Share Your Personal Information With").

Some of these third parties may be based outside the country where we originally collected your personal information. For more information, including how we safeguard your personal information when this occurs, see "International Transfers of Personal Information" below.

12. International Transfers of Personal Information

To bring you our Site and services, FreshOS operates globally. Therefore, it is sometimes necessary for us to share your personal information outside the country where we originally collected it, including:

  • With our offices in the United States;

  • With your and our service providers located throughout the world;

  • If you are based outside the EEA; or

  • Where there is an international dimension to the services we are providing to you.

These transfers may be subject to special rules under local data protection laws.

The countries where your personal information may be transferred do not always have the same data protection laws as the country where we originally collected the information. In particular, the United States follows a sectoral model of privacy protection, relying on a mix of legislation, governmental regulation, and self-regulation. However, we will ensure that all transfers comply with data protection laws and that personal information remains secure.

If you are located outside the United States, we will only transfer your personal information if:

  • You provide explicit consent;

  • The country receiving the personal information has been granted an adequacy decision by your local supervisory authority; or

  • We have put in place appropriate safeguards, such as standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

FreshOS is headquartered in the United States and utilizes service providers both in the U.S. and globally. As such, we and our service providers may transfer or access your personal information in jurisdictions that may not provide the same level of protection as your home country.

Where the laws of your country allow, by using our Site or services, you consent and authorize FreshOS to transfer, store, and process your information in the United States and other countries where we operate. If you do not want your personal information transferred to the United States or other jurisdictions, please do not submit any information to us or use our services.

If you would like further information, please contact us (see "How to Contact Us" below).

13. Your Rights and Choices

If you are located in the European Economic Area (EEA), the UK, Canada, or the states of California, Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, or Virginia, please refer to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

14. Third-Party Websites

If, during your interactions with our Site, you are linked or directed to a third-party website, or click on a third-party link, FreshOS cannot control what information you may provide to that party or how that party may use or disclose any information you provide.

This does not represent an endorsement by FreshOS of any third-party website, the content offered on it, or the products or services provided by that third party. We do not control nor are we responsible for such third-party websites, products, or service offerings.

We urge you to exercise caution before providing your personal information to any third-party website and to review its privacy policy for details on how your data is handled.

If you have any complaints, claims, concerns, or questions regarding a third-party website or its privacy practices, please contact the site administrator for that website directly.

15. Changes to this Privacy Policy

‍This Privacy Policy was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.

16. How to Contact Us

‍Please contact us by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

Our contact details are shown below:

FreshOS LLC

6636 W. William Cannon Dr, #536

Austin, TX 78735

Email: contact@freshos.co

PRIVACY NOTICE ADDENDUM

This Privacy Notice Addendum (“Notice”) supplements the information contained in the FreshOS Privacy Policy and applies solely to all visitors, users, and others located in the European Economic Area (EEA), the UK, Australia, Canada, or the states of California, Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, and Virginia("consumers" or "you").

We adopt this Notice to comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK GDPR, the California Shine the Light Law, the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Montana Consumer Data Privacy Act of 2024, the Oregon Consumer Privacy Act of 2024, the Texas Data Privacy and Security Act of 2024, the Utah Consumer Privacy Act of 2022, the Virginia Consumer Data Protection Act of 2023, and other applicable privacy and data protection laws (collectively, the "Statutes").

Any terms defined in the Statutes will have the same meaning when used in this Notice. Any terms used in this Noticebut not explicitly defined shall have the meaning provided in the FreshOS Privacy Policy.

As further set forth in our Privacy Policy, we may collect certain information that is:

  1. Linked or reasonably linkable to an identified or identifiable individual or natural person.

  2. Identifies, relates to, describes, or is capable of being associated with a consumer or household.

  3. Defined under the applicable Statutes as “Personal Data” or “Personal Information,” as described in our Privacy Policy.

17. Shine the Light Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits individuals who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with whom we shared personal information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.

18. Personal Information Disclosed for a Business Purpose

Categories of Personal Information Disclosed for a Business Purpose in the Past 12 Months

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information:

  • Category A - Identifiers

  • Category B - Customer records information

  • Category F - Internet or other electronic network activity information

  • Category I - Professional or employment-related information

19. Your Rights Under the CCPA

Under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and other applicable privacy and data protection laws, you may have the right to exercise certain rights regarding your personal information free of charge.

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of personal information we have collected about you.

  • The categories of sources from which we collect personal information.

  • Our business or commercial purpose for collecting or selling personal information.

  • The categories of third parties with whom we share personal information, if any.

  • The specific pieces of personal information we have collected about you.

However, we are not required to:

  • Retain any personal information collected for a single, one-time transaction if we do not retain such information in the normal course of business.

  • Reidentify or otherwise link any data that is not maintained as personal information.

  • Provide the same personal information more than twice in a 12-month period upon request.

Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose

If we sell or disclose personal information to a third party for a business purpose, you have the right to request:

  • The categories of personal information that we have sold and the categories of third parties to whom we sold the information.

  • The categories of personal information we disclosed for a business purpose.

Right to Opt-Out of the Sale of Personal Information

You have the right to opt out of the sale of your personal information. If you choose to opt out, we will refrain from selling your personal information unless you provide explicit authorization at a later time. To opt out, please email us at contact@freshos.co with your request.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to opt out of the use and disclosure of your sensitive personal information for anything other than providing requested goods or services. However, FreshOS does not collect sensitive personal information.

Right to Correction

You have the right to request that we correct any inaccurate personal information maintained by us. Upon receiving a verifiable request, we will use commercially reasonable efforts to correct the inaccuracies.

Right to Deletion

You have the right to request the deletion of your personal information from our records and the records of any service providers we use. However, we may deny your deletion request if retaining the information is necessary to:

  • Complete a transaction, fulfill a warranty, or provide a service you requested.

  • Detect security incidents, prevent fraud, or prosecute those responsible for such activity.

  • Debug and repair errors that impair existing functionality.

  • Exercise or ensure the free speech rights of other consumers.

  • Comply with legal obligations, such as the California Electronic Communications Privacy Act.

  • Conduct public or peer-reviewed scientific, historical, or statistical research in the public interest (with your informed consent).

  • Enable internal uses that align with your expectations based on your relationship with us.

  • Otherwise, use your personal information in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. This means we cannot:

  • Deny you goods or services.

  • Charge different prices or rates for goods or services (unless permitted based on the value your personal data provides to our business).

  • Provide a different level or quality of service to you.

  • Suggest that you will receive a different price, rate, or service quality.

However, we may offer different prices, rates, or service levels if they are reasonably related to the value of your personal information.

20. Your Rights Under Other State Privacy Laws

Residents of Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, and Virginia have specific rights regarding their personal information. These rights vary by state but may include the following:

Right to Opt-Out

You may have the right to opt out of the processing of your personal data for:

  • Targeted advertising.

  • The sale of personal data.

  • Profiling in furtherance of decisions that produce legal or similarly significant effects.

Right of Access

You may have the right to confirm whether we are processing your personal data and to access a copy of the data we maintain. Some states may limit the number of times you can request this information within a specific timeframe.

Right to Correction

You may have the right to request the correction of inaccuracies in your personal data, taking into account the nature of the data and its purpose. This right applies to residents of Colorado, Connecticut, Montana, Oregon, Texas, and Virginia.

Right to Deletion

Residents of Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, and Virginia may have the right to request that we delete their personal data or information collected about them.

Right to Data Portability

You may have the right to request a copy of your personal data in a portable and readily usable format that allows you to transfer it to another entity without hindrance. This right applies to Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, and Virginia residents.

Right to Appeal

If we decline your request to exercise any of these rights, we will notify you. You may have the right to appeal our decision within a reasonable period. If you believe your rights were violated, you may submit an appeal following the instructions in our response to your request.

21. Your Rights Under the GDPR and the UK GDPR

If you reside in the European Economic Area (EEA) or the UK, you may have additional rights under applicable data protection laws, including:

Right to Access

You have the right to request and receive a copy of your personal information maintained by FreshOS.

Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal information.

Right to Be Forgotten (Erasure)

You may request that we delete your personal data if:

  • It is no longer necessary for the purpose for which it was collected.

  • You withdraw consent, and we have no other legal basis to process your data.

  • You object to data processing, and we have no overriding legitimate reason to continue.

  • The data was unlawfully processed or must be deleted to comply with legal obligations.

However, we may decline deletion requests if processing your personal data is necessary to:

  • Complete a transaction or fulfill a contract with you.

  • Comply with legal obligations (e.g., tax reporting, law enforcement requests).

  • Detect or prevent fraud, security breaches, or other illegal activities.

  • Exercise or defend legal claims.

Right to Restriction of Processing

You may request that we restrict processing of your personal data in certain circumstances, such as when you contest its accuracy or object to its processing.

Right to Data Portability

You may have the right to receive your personal data in a structured, commonly used, and machine-readable formatand to transmit that data to another controller where technically feasible.

Right to Object

You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests. If you object, we will cease processing unless we demonstrate compelling legitimate grounds.

Right to Lodge a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with the appropriate supervisory authority in your country.