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FRESHBOOKS Privacy and Security:

Privacy Policy
Last Updated: June 2, 2022

This is the Privacy Policy of (i) the FreshBooks


website: https://www.freshbooks.com (the “Site”), (ii) any other website where
this Privacy Policy is hosted that is owned and operated by 2NDSITE Inc.
(together with our affiliates and subsidiaries, including FreshBooks USA Inc,
FreshBooks Netherlands B.V., FreshBooks UK Ltd., and any future affiliates
or subsidiaries, (“FreshBooks”, “we”, “us”, “our” and terms of similar meaning)
(such other websites are, for purposes of this Privacy Policy included in the
definitions of “Site”); and (iii)  our related products and services. It describes
the information that we collect from you as part of the normal operation of our
Site, and how we disclose and secure this information. It also describes your
choices regarding use, access and correction of your personal information.

By accepting the Privacy Policy in registration or by visiting and using the Site,
you expressly consent to our collection, use and disclosure of your personal
information in accordance with this Privacy Policy. This Privacy Policy is
incorporated into and subject to our Terms of Service.

In this Privacy Policy, we use the following terms to describe different types of
visitors to our Site. Our customers are called “Subscribers” and our
Subscribers’ customers are called “Customers”. We use the word “staff” to
describe persons to whom Subscribers give “staff” access on the Site.
Together with registered users of our forum or other interactive areas of the
Site, these people are collectively described in this Privacy Policy as “Users”
of our Site.

FreshBooks may also provide other web sites and software, including without
limitation freeinvoicecreator.com, and the services provided by or through
such web sites and software.  These Terms also govern your use of such web
sites, software and services which, for purposes of these Terms (and the
FreshBooks’ Privacy Policy referred to in Section 1 below) are included in the
definitions of “Site”, “Application” and “Services”.

What Information Do We Collect?

Our primary purpose in collecting personal information from you is to provide


you with a safe, smooth, efficient, and customized experience. This allows us
to provide services and features that most likely meet your needs, and to
customize our service to make your experience safer and easier. We only
collect personal information about you that we consider necessary for
achieving this purpose.

In general, you can browse the Site without telling us who you are or revealing
personal information about yourself. Once you become a User, we may
require you to provide various contact and identity information, billing
information, and other personal information as indicated on the relevant forms
on the Site (which vary, depending on what kind of User you are). Where
possible, on these forms we indicate which fields are required and which fields
are optional.

In addition, as you use the Site, you can from time to time enter or send to us
personal information. For example, if you are a Subscriber, you can enter your
own timesheet and other billing information, and if you are a Customer you
can enter information about payment of any invoice submitted by a
Subscriber. As you use the Site you can also from time to time enter personal
information about third parties relevant to the services we provide. For
example, if you are a Subscriber, you can (within the context of the services)
enter personal information about your Customers or your staff.

You always have the option to not provide information by choosing not to
become a User or by not using the particular feature of the Site for which the
information is being collected.

If you are a Subscriber, we collect your credit card information for billing
purposes. And if you are a Customer who wishes to pay amounts to a
Subscriber on a recurring basis, we collect and store your credit card
information for payment purposes.

Some of our pages where personal data is collected utilize framing techniques
to serve content  to you from our partners while preserving the look and feel of
our site. Please be aware that you are providing your personal information to
these third parties and not to www.freshbooks.com (in each case the relevant
third party will be identified to you via that section of the website).

We also make use of third party companies to process personal information


as needed for marketing or analytical purposes that enhance our existing
services and programs. 
Technologies such as: cookies and similar technologies are used by
FreshBooks and our partners (e.g., advertising, marketing and analytics),
affiliates, or other service providers. These technologies are used in analyzing
trends, administering the site, tracking users’ movements around the site and
to gather demographic information about our user base as a whole. We may
receive reports based on the use of these technologies by these companies
on an individual as well as aggregated basis.

We use cookies to remember users’ settings, store login addresses,


authenticate users, run website experiments, and store analytics data. Users
can control the use of cookies at the individual browser level. If you reject
cookies, you may still use our site, but your ability to use some features or
areas of our site may be limited.

We partner with a third party to either display advertising on our Web site or to
manage our advertising on other sites. Our third party partner may use
technologies such as cookies to gather information about your activities on
this site and other sites in order to provide you advertising based upon your
browsing activities and interests. If you wish to not have this information used
for the purpose of serving you interest-based ads, you may set your
preferences by clicking here. Please note this does not opt you out of being
served ads. You will continue to receive generic ads.

We, or our designated third party service provider, may from time to time
contact you by telephone. Such calls may as indicated by us, and with your
consent, be monitored, recorded, stored and used for the purposes specified
in such calls.

How We Use Your Information

We use your personal information to provide to you the services offered by the
Site; resolve service and billing disputes; troubleshoot problems; bill any
amounts due from you; measure consumer interest in our products and
services, inform you about online and offline offers, products, services, events
and updates; deliver information to you that, in some cases, is relevant to your
interests, such as product news; customize your experience; detect and
protect us against error, fraud and other criminal activity; enforce our Terms of
Service; provide you with system or administrative messages, and as
otherwise described to you at the time of collection. On occasion we use email
address or other contact information to contact our Users to ask them for their
input on our services, to forward to them media opportunities, and even to
invite them to dinner.
We may also use personal information about you to improve our marketing
and promotional efforts, to analyze Site usage, to improve our content and
product offerings, and to customize the Site’s content, layout, and services.
These processes include automated decision-making and profiling
information. The intention of the usage is to improve the Site and the
FreshBooks application and better tailor it to meet your needs, so as to
provide you with a smooth, efficient, safe and customized experience while
using the Site.

Sharing of Your Information

We will share or disclose your personal information with third parties only in
the ways that are described in this privacy policy, including as follows:

 Subscribers and Customers Information: In the normal operation of


the Site Subscriber timesheets (including information entered by “staff”
members) and invoices are disclosed to the applicable Customers, and
Customer information is disclosed to the applicable Subscriber. In
general, information you enter on the Site is available to the other
persons – whether they are Customers, Subscribers, staff members or
others – to whom you give access to your account or to whom you give
access to the information through the normal operation of the Site.
 Payment Information: We use credit card and other personally
identifiable information (such as payment processor email addresses)
you submit to us on the Site, and other information that we collect, as
required, to process payments you make through the Site through our
payment processor intermediaries. We do not store credit card or other
payment method information unless the Subscriber or their Customers
choose to enter credit card information for use in the FreshBooks
recurring profiles module; in all other cases our payment processors
have the sole and complete responsibility for the storage of credit card
and payment information. We may also share personally identifiable
information with our payment processor intermediaries for risk
management and fraud prevention.
 Related third party products and services: From time to time, we
may offer you opportunities to receive related products and services that
integrate with, or complement, the services we offer via the Site. For
example, you may have the opportunity to request financial products or
services, including loans, from third parties. We will only share your
information with such third parties if you choose to request their
products or services (or to be assessed for eligibility to receive such
products or services). If you do choose to request such products or
services, we will provide your information to the relevant third party on
your behalf, as required to provide the products or services you have
requested. We do not control the use, storage, retention, processing, or
disclosure of your information by such third parties, and this Privacy
Policy will not apply to them. Your relationship with these third parties
will generally be subject to their separate terms and conditions as well
as privacy policies or statements, and we recommend that you carefully
review these documents before requesting their products or services.
 Aggregated Data: We will create statistical, aggregated data relating to
our users and the Service for analytical purposes. Aggregated data
includes data derived from Personal Information and obtained by
FreshBooks from other sources in aggregated, anonymous form and
does not identify any individual (such data is referred to as “Aggregate
Information”). Subject to applicable laws and regulations, we use
Aggregate Information to understand our customers and to develop,
improve and/or market our Services. We may provide Aggregate
Information to third parties.
 Forum: If you post on our forum or blog your username and other
information you include is displayed in your postings or comments, and
is therefore available to the public. All of your activities in the public
areas of the forum will be identifiable to your User ID, and other people
can see your published content. If you disclose personal information in
any posting in our forum or blog and wish to have it removed, please
contact us at the support contact information listed below, and posted
on the Site. Our blog commenting system is also managed by a third
party application that may require you to register to post a comment.
You will need to contact or login into the third party application if you
want the personal information that was posted to the comments section
removed. To learn how the third party commenting application uses
your information, please review their privacy policy.
 Subsidiaries, Affiliates, and Service Providers: We may from time to
time use the services of affiliates, subsidiaries and unrelated service
providers in the operation of the Site, and may disclose personal
information to them in the course of our use of their services. For
example, we may use the services of third party hosting companies to
host the operation of the Site. This may involve the hosting of data,
including personal information, on servers operated by those hosting
companies. We take care to use only service providers that we believe
are reputable, have equivalent or better security safeguards in place
than us, and able to live up to our and your expectations, including
about the handling of confidential information. These companies are
authorized to use your personal information only as necessary to
provide these services to us.
 Legal Requests and Business Transitions, Emergencies: In certain
situations, FreshBooks may be required to disclose personal data in
response to lawful requests by public authorities, including to meet
national security or law enforcement requirements. FreshBooks may
disclose your personal information (a) to any governmental authority as
part of an investigation to determine our compliance with any applicable
law, rule, or regulation (including privacy laws, rules, and regulations),
(b) in response to a court order, subpoena, discovery request, or other
lawful judicial or administrative proceeding, (c) as otherwise required or
permitted under any applicable law, rule, or regulation, and (d) in good
faith, to protect or defend the rights or property of FreshBooks and other
users and (e) if FreshBooks is involved in a merger, acquisition, or sale
of all or a portion of its assets, you will be notified via email and/or a
prominent notice on our Web site of any change in ownership or uses of
your personal information, as well as any choices you may have
regarding your personal information.
 FreshBooks will not purchase consent, or sell, rent or share consent to
opt-in to our mobile SMS/texting program.
For further details on the specific third party usage of our data, including a list
of the partner organizations with whom Aggregate Information may be shared,
please reach out to our team at privacy@freshbooks.com.

Your Use of Other Persons’ Information

In order to facilitate the services provided by the Site, the Site allows you in
certain circumstances to give other Users limited access to the personal
information of other persons. For example, if you are a Subscriber, you may
use the Site to give access to a staff member to the personal information of
your Customers. By entering into our Terms of Service, you agree that, with
respect to the personal information of other persons that you collect, use and
disclose on the Site, you have all necessary consents and rights to collect,
use and disclose that information as described in this Privacy Policy from time
to time, and you agree that the indemnity you give to us in the Terms of
Service applies to any non-compliance by you with the foregoing.If you
choose to use our referral service to tell a friend about our site, we will ask
you for your friend’s name and email address. We will automatically send your
friend a one-time email inviting him or her to visit the site. FreshBooks stores
this information for the sole purpose of sending this one-time email, tracking
the success of our referral program, and compliance with laws. Your friend
may contact us at privacy@freshbooks.com to request that we remove this
information from our database.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document


only addresses the use and disclosure of information we collect from you. To
the extent that you disclose your information to other parties through the Site,
whether they are Subscribers or Customers or otherwise, different rules may
apply to their use, collection and disclosure of the personal information you
disclose to them. Since we do not control the information use, collection or
disclosure policies of third parties, you are subject to their privacy policies. We
encourage you to ask questions before you disclose your personal information
to others.

Consent for Withdrawal

We provide you a way for you to withdraw your information being processed
for individuals within the European Economic Area (EEA) and the State of
California.

Contact us at privacy@freshbooks.com to initiate the steps required. We will


verify your information prior to processing and proceed with the steps
necessary within the applicable laws and regulations.

If you are not a resident of the EEA or the State of California but wish to no
longer be subscribed to emails or direct mail campaigns, please reach out to
our support team at help@freshbooks.com

Correcting, Updating, and Transferring Your Personal Information

Upon written request FreshBooks will provide you with information about what
personal information we have about you. To review, delete, and update your
personal information to ensure it is accurate, you may login into your account
to make the changes, or you may contact us at privacy@freshbooks.com. We
will respond to your request within a reasonable timeframe, and typically
within one month of the request being made. We may ask you for further
information from you to help us respond to your request, including asking for
government-issued identification to verify your identity before we provide the
personal data. If you are a EEA resident requesting the porting or an export of
your information, you may reach out to us at privacy@freshbooks.com and we
will proceed with the steps necessary.

Account Deletion

FreshBooks is a complex business network that connects millions of users.


FreshBooks manages a business eco system that brings together contractors,
companies and customers. This network relies on the exchange and sharing
of information that is important to others in your network. Tracked hours, sent
invoices, paid invoices, contractor invoices are all vital to other people that
work with you. These are the official history of work done and moneys paid.
The complexity and connected nature of the system requires that this history
exists for as long a time as necessary to accommodate proper function and
accounting for the other systems that you have connected to via contracting
hours, invoices, estimates. FreshBooks will reasonably assure that
information, where it is no longer required for the proper functioning of the
service, will be deleted in a compliant manner and will consider any deletion
request within the requirements of applicable law.

When a customer chooses to close an account we will remove your


information from our marketing and billing systems. This will ensure that there
are not further mailings or billings directed towards the canceled user.

Data Retention

We will retain your information for as long as your account is active or as


needed to provide you services.

Our goal is to retain your information as necessary to comply with our legal
obligations and accepted accounting principles, resolve disputes, and enforce
our agreements; this retention period may extend past the point at which you
close your account.

The criteria that will be for determining periods of retention will be based on
the type of data. For example, data relevant to accounting information will be
retained for at least 7 years, whereas temporary cookie data of a web visitor
may not be retained at all.

International Transfer of Personal Information


Other than as specified within this Policy, we do not share your personal
information with third parties. Where we do transfer your personal information
to third parties or service providers, appropriate arrangements will be made in
order to ensure correct and secure data processing in compliance with
applicable data protection law.

We store personal information about Website Visitors and Subscribers within


Canada, the United States and in other countries and territories. To facilitate
our global operations, we may transfer and access such personal information
from around the world, including from other countries in which FreshBooks
has operations. Therefore, your personal information may be processed
outside of the UK, the EEA and in countries which are not subject to an
adequacy decision by the UK Secretary of State or the European Commission
and which may not provide for the same level of data protection as the UK or
the EEA.

In this event, we will ensure that the recipient of your personal information
offers an adequate level of protection, for instance by entering into standard
contractual clauses for the transfer of data as approved by the European
Commission (Art. 46 GDPR), or we will ask you for your prior and explicit
consent to such international data transfers.We have implemented safeguards
to ensure an adequate level of data protection where your personal
information is transferred to countries outside the EEA. For further details on
the transfer of your personal information, including a list of the organizations
with whom said information may be shared, please reach out to our team
at privacy@freshbooks.com.

Security Safeguards

For more details on how we protect your data, please see


our https://www.freshbooks.com/policies/security-safeguards page.

Supplemental Policy Information

Invitations: 

You have the opportunity to invite others to work with you through your
FreshBooks account. To do that, FreshBooks asks you to import or to
manually enter your contacts’ email addresses. As you direct, we then send
them an invitation on your behalf or other notices reflecting changes you make
to their status in your account.
If you click on a link to a third party site, you will leave the FreshBooks site
and go to the site you selected. If you elect to use a third party product or
service in conjunction with FreshBooks, you yourself enter into a license
agreement with the third party for use of their product or service and their use
of your data. This will be notified to you at the relevant time. Because we
cannot control the activities of third parties, we cannot accept responsibility for
any use of your personal information by such third parties, and we cannot
guarantee that they will adhere to the same privacy practices as FreshBooks.
We encourage you to review the privacy policies of any other service provider
from whom you request services. If you visit a third party website that is linked
to a FreshBooks site, you should read that site’s privacy policy before
providing any personal information.

With your consent we may post your testimonial along with your name. If you
want your testimonial removed please contact us at privacy@freshbooks.com.

Our Web site includes Social Media Features, such as the Facebook and
Twitter buttons and Widgets, such as the Share this button or interactive mini-
programs that run on our site. These Features may collect your IP address,
which page you are visiting on our site, and may set a cookie to enable the
Feature to function properly. Social Media Features and Widgets are either
hosted by a third party or hosted directly on our Site. Your interactions with
these Features are governed by the privacy policy of the company providing it.

Residents of Canada

Personal information (as the term is defined in the Personal Information


Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be
collected, stored, used and/or processed by the FreshBooks in compliance
with the FreshBooks’s obligations under PIPEDA.

California Residents

The California Consumer Privacy Act (“CCPA”), which is effective as of


January 1, 2020, regulates how we handle personal information of California
residents and gives California residents certain rights with respect to their
personal information.

FreshBooks is both a “business” and a “service provider” under the CCPA.


The following supplemental privacy policy applies to information we collect in
our role as a business—this is when we interact directly with you.
When we act as a service provider (for example, by providing our services to
another company that you interact with), we follow the instructions of the
business that engaged us with respect to how we process your personal
information. If you would like more information about how your personal
information is processed by other companies, including companies that
engage us as a service provider, please contact those companies directly.

This supplemental privacy policy is effective as of January 1, 2020, shall apply


only to residents of California, and may be subject to change. The general
privacy policy shall continue to apply to the extent that it applies to you as a
resident of California. If you are a resident of California, we are required to
disclose certain uses and disclosures in a certain format, as well as to inform
you of certain rights you may have. Any capitalized terms used in this
supplemental privacy policy shall have the same meaning as in the general
privacy policy.

European Economic Area (EEA) and United Kingdom (UK) Visitors

If you are a visitor from the European Economic Area (“EEA”) or the United
Kingdom (“UK), our legal basis for collecting and using the personal
information described above will depend on the personal information
concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where
we need the personal information to perform a contract with you (e.g. to
provide you with our Services), where the processing is in our legitimate
interests and not overridden by your data protection interests or fundamental
rights and freedoms, or where we have your consent. In some cases, we may
also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal


requirement or to perform a contact with you, we will make this clear at the
relevant time and advise you whether the provision of your personal
information is mandatory or not (as well as of the possible consequences if
you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our


legitimate interests (or those of any third party), we will make clear to you at
the relevant time why we need to use your personal information. If we process
personal information in reliance on your consent, you may withdraw your
consent at any time.
If you have questions about, or need further information concerning, the legal
basis on which we collect and use your personal information in any specific
instance, please contact us using the contact details provided under the
“Contact Us” section below.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information


practices. If we make any material changes we will notify you by email (sent to
the email address specified in your account) or by means of a notice on this
Site prior to the change becoming effective. We encourage you to periodically
review this page for the latest information on our privacy practices.

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