Terms & Conditions

Terms of Access, Cookies and Copyright

By accessing this Website you agree to be bound by these terms and conditions which may be modified from time to time. Any changes to these terms and conditions will be posted on this Website. You are advised to review this page on a regular basis.

Information about FREO Group

References to FREO Group or FREO in this Website are to the group of companies comprising FREO Group Sarl (“FREO Group” or “FREO”), a Luxembourg limited company with registration number LU24267561 and its subsidiaries and affiliates, including, but not limited to:

FREO Group (UK) LLP, a limited liability partnership registered in England (OC395596)
FREO Financial & Real Estate Operations GmbH, a limited liability company by shares registered in Germany (DE184296868)
FREO France SAS, a limited liability company by shares registered in France (387529811)
FREO Investments Spain, SL, a limited liability company registered in Spain (B87323994)
FREO Switzerland AG, a public limited company registered in Switzerland (CHE144518142)
FREO US Management LLC, a limited liability company registered in Delaware, USA (9605329-0161)

You can contact FREO by email at info@freogroup.com or by mail at EBBC 6D, route de Tréves, L-2633 Senningerberg, Luxembourg.

Use of this Website

This Website may be accessed and used only in accordance with these terms and conditions and only in respect of your personal or internal business use. The information, data and graphics (“Information”) on this Website are provided as a source of general information relating to FREO only and do not constitute legal, tax, credit, financial or other professional advice. By making the Information available to you, FREO is not advising you or making any recommendation with respect to any of the FREO investments, past, present or future.

Limitations of Liability

No representation is made that the Information is up-to-date, accurate, complete or reliable. Information may not have been updated since its original publication date and may not reflect current circumstances. Accordingly, by accessing this Website you agree that you will not place any reliance upon the Information. No assurance is given as to the continued availability of this Website or its contents. The Information and this Website are provided without any warranty of any kind and all representations, warranties, conditions and other terms express or implied by statute, common law or otherwise are excluded to the fullest extent permitted by law. FREO shall not be liable under any circumstances for any loss or damage of any kind including, without limitation, any direct, special, indirect or consequential loss or damage, in each case arising out of or in connection with the access to or use of this Website or the Information (save that this does not affect FREO’s liability for death or personal injury caused by FREO’s negligence, FREO’s liability for fraudulent misrepresentation, or any other liability which may not be excluded or limited by law). Where links to third party websites are provided, this is for convenience only and FREO has no control over, does not endorse and shall not be responsible for the content of such sites. Neither you nor any third party on your behalf shall link into this Website without the express written consent of FREO.

Data Protection Section

We (FREO Group Sarl), as data controller, are dedicated to ensuring the protection of your personal data you entrust us with. In the context of the enforcement the new regulation on the protection of personal data (General Data Protection Regulation, “GDPR”) on 25th May 2018, we are committed to ensure that personal data collected online is appropriately processed and protected.

This notice, designed as a proof of transparency, is a practical summary of how we use, share and protect the personal data collected on our website.

What Data do we Collect and Why

We obtain personal information about you if you choose to provide it — for example, to contact us via mail or social networks. If you choose to register or login to our social network profile using a third party service that authenticates and connects you to with us (e.g., LinkedIn or Twitter), we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social network provider, so please review the privacy statement or policy of the applicable service.

When we collect your personal data, we will process them mainly to permit and facilitate our business relationship with you as prescribed contractual agreement. Other purposes are described in the section below (“On what legal basis”). Your personal data will not be used for other purposes, unless we obtain your consent, or unless required or permitted by law.

We value the protection of children data, especially in the online context. Our websites are not designed for or directed at children under the age of 13. We never knowingly collect or process data from anyone under the age of 13, except as part of an agreement to provide relevant services and in this case only with the appropriate consent from his/her legal guardians.

Automatic Collection of Personal Information

We (and our service providers) use cookies and tracking tools to automatically collect certain types of data when you visit us online. Collecting this data allows us to customize your online experience, improve the performance, usability and effectiveness of our websites, and to measure the effectiveness of our marketing activities.

What is a cookie?

A cookie is a small text file which is placed on your computer by websites that you visit. Cookies are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.

Some cookies expire upon the termination of each session and other cookies may be stored to your computer’s hard drive for longer periods, depending on their purpose and providers.

Tracking cookies

These allow FREO to monitor its website’s visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage.

Your choices with regards to cookies’ usage on well-known browsers

Well-known browsers give you some control over most cookies through the browser settings. To find out more about cookies, which one are set in your browser, how to manage and delete them, please visit: www.allaboutcookies.org or www.aboutcookies.org.

On what Legal Basis

We generally collect only the personal information necessary to fulfill the aforementioned purposes. Where further, optional information is required/needed, you will be notified of this at the point of collection.

EU and Luxembourg data protection law allows us to process personal information, as long as we have a legal basis to do so. It also requires us to inform you on those legal basis. We therefore rely on the following grounds when processing your data:

  • Compliance with legal obligations: this is when we are required to process your personal data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  • Safeguard our legitimate interests: this is when we process your personal data to ensure that we keep running a lawful, reliable and sustainable business. This is done as long as it doesn’t outweigh your interests; Examples of the “legitimate interests” referred to above are:
    • Providing visitors with sound information and/ or services,
    • Providing visitors with a tailored experience,
    • Monitoring and improving the performance of our websites based on usage patterns.
  • On the basis of your consent: this is when for specific activities, your permission is required for further processing. In that case, you could revoke that freely at any time by contacting our data protection office. For example, you might opt-in for particular services or communications, such as an e-newsletter. You will then be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove you from the communication list promptly.

Transfer of Personal Information

Transfer within the EU

We share your personal data with other member firms of FREO Group as part of international engagements, and where required or desirable to meet our legal and regulatory obligations. Other transfers’ purposes include providing services to us and to you, for example hosting our websites, performing Anti-Money Laundering checks and otherwise as required in order to continue to run our business.

Transfers to third parties

Data will only be transferred to countries outside of the EU or the EEA (so called third countries) if required for the execution of our contractual obligations with you or as prescribed by law (e. g. reporting obligations under tax law), if you have given us your consent or in the context of a subcontracting agreement.

If services are required from providers outside of the EU or EEA, we shall ensure their compliance with the data protection regulation in Europe and our applicable standards on data protection. In such case, we shall necessary measures to ensure end-to-end protection to related data during their transfer.

We will not transfer your personal data to any third parties for their own business use (e.g. marketing).

Your Rights with Regards to your Data

You benefit of the following rights in relation with your personal data we process:

  • Access your data considering that you provide us with proof of your identity,
  • Request its rectification,
  • Request their erasure where applicable,
  • Restrict or object to their processing when we are not entitled to process them further,
  • Request a copy of your data or their transfer to another data controller,
  • Lodge a complaint with supervisory authority, the Commission Nationale pour la Protection des Données (“CNPD”).

You can make a request or exercise these rights free of charge by using following address:

FREO Group S.a.r.l
Data Protection Office
6D Route de Trèves, 2633 Senningerberg, Luxembourg
E: privacy@freogroup.com

We will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Data Security and Conservation

We take reasonable security measures to protect your data from unauthorized access, alteration or loss. However and despite our best efforts, we cannot ensure of absolute security therefore we recommend that you take necessary steps to ensure a secure browsing.

We also make reasonable efforts to retain personal information only for so long as necessary to comply with our contractual, legal, regulatory requirements, or you request that your data be deleted. The period for which data is retained will depend on the specific nature, circumstance and purpose for which the data was collected.

Changes to this Notice

We might modify this notice from time to time to reflect our most current data protection practices. In such case, any changes affecting you will be communicated to you on our websites in a timely manner.

Policy Questions and Enforcement

We are committed to protecting your online privacy when using our websites. If you have questions or comments with regards to this notice or other data protection specific questions, please contact us at privacy@freogroup.com.

Intellectual Property Rights

Except as indicated in this Website, FREO or its licensors own all intellectual property rights in this Website and all Information. Your right to use the Information is strictly limited to your authorized use of this Website in accordance with these terms and conditions. The Information may not otherwise be reproduced, distributed, transmitted to any person or incorporated in any way into another document or material without FREO’s prior written permission.

Governing Law

These Terms and Conditions are governed by the laws of England and by accessing this Website you submit to the exclusive jurisdiction of the English Courts.