Privacy Policy – Freya & Co

COMPLEET IS SERVICES LTD
Suite 3, Floor 2, Valley Tower, Valley Road
Birkirkara, BKR 9022 – Malta
VAT: MT15147837 | Reg. C23032
Email: info@freyanco.com

Last updated: December 11, 2025

  1. Introduction

COMPLEET IS SERVICES LTD (“we,” “us,” “our,” or “Company”) operates the Freya & Co website (the “Site”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Site.

  1. Information We Collect

2.1 Contact Form Information

When you submit our contact form, we collect the following personal data:

  • Full name
  • Surname
  • Email address
  • Phone number (optional)
  • Message content

Purpose: We collect this information solely to respond to your inquiries, provide information about our services, and prepare quotes or invoices if requested.

Legal basis: Processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract, and for compliance with legal obligations (e.g., tax/accounting requirements).

Retention: We retain this information only for as long as necessary to fulfill your request or for the duration required by applicable law. If you request a quote or enter into a contract, we may retain data for accounting and tax purposes as required by law.

2.2 Newsletter Subscription

If you subscribe to our newsletter via Mailchimp, we collect:

  • Email address
  • Any additional information you voluntarily provide

Purpose: To send you newsletters, news, and marketing communications about our services.

Legal basis: Your explicit consent to receive these communications.

Retention: We retain your email until you unsubscribe or request deletion.

Third-party processor: Mailchimp (see section 5 for details on data transfers).

2.3 Analytics Data

When you visit our Site, we automatically collect certain information through Google Site Kit/Google Analytics:

  • Number of visits and page views
  • General information about your device (browser type, operating system)
  • Approximate geographic location (country/city level)
  • How you interact with pages (clicks, scroll depth, time on page)

Purpose: To understand Site usage, monitor Site health and performance, and improve user experience.

Legal basis: Our legitimate interest in analyzing Site performance and user behavior.

Retention: Google Analytics data is typically retained according to Google’s retention settings (default 26 months).

Configuration: We configure Google Analytics with IP anonymization enabled to limit data collection.

2.4 Social Media Links

Our Site contains links to our social media profiles (Instagram, LinkedIn, Facebook, etc.). Clicking on these links does not transmit your data to us, but may transmit information to the respective social media platforms according to their own privacy policies.

2.5 Embedded YouTube Videos

Our Site may embed YouTube videos. When you view embedded videos, YouTube may place cookies and collect data about your interaction with the video according to YouTube’s privacy policy. YouTube operates under Google’s privacy policies.

  1. How We Use Your Information

We use your personal data for the following purposes:

  • To respond to your inquiries and provide information or quotes
  • To fulfill contracts and complete transactions (including future e-commerce functionality)
  • To send newsletters (if you have subscribed and provided consent)
  • To comply with legal obligations (e.g., accounting, tax, regulatory requirements)
  • To improve our Site and services (through analytics)
  • To prevent fraud and maintain Site security

We do not use your data for marketing or profiling purposes beyond sending newsletters to those who have explicitly subscribed.

  1. Data Sharing and Disclosure

4.1 Third-Party Service Providers

We may share your personal data with the following third parties only as necessary to provide our services:

Service Provider

Purpose

Data Transferred

Mailchimp

Newsletter management and delivery

Email address

Google Site Kit / Google Analytics

Site analytics and performance monitoring

Anonymized visit data, browser info, location (approximate)

Hostinger

Web hosting and site infrastructure

Site data and access logs

YouTube

Video hosting (if applicable)

Data related to video viewing (per YouTube’s privacy policy)

Each of these providers is a Data Processor under GDPR and has entered into data processing agreements with us.

4.2 Legal Requirements

We may disclose your personal data if required to do so by law or if we believe in good faith that such disclosure is necessary to:

  • Comply with legal obligations, court orders, or government requests
  • Enforce our Terms of Service and other agreements
  • Protect the security or integrity of our Site
  • Protect the rights, privacy, safety, or property of our Company, users, or the public

4.3 No Sale of Data

We do not sell, trade, or rent your personal information to third parties for their marketing purposes.

  1. International Data Transfers

Your data may be transferred to, stored in, and processed in countries other than your country of residence, including countries outside the European Economic Area (EEA). These countries may have data protection laws different from those of your home country.

Specifically:

  • Mailchimp (USA) transfers data under Standard Contractual Clauses approved by the EU.
  • Google services (USA) may transfer data internationally; Google provides appropriate safeguards.

By using our Site, you consent to the transfer of your information to countries outside the EEA as described in this Privacy Policy.

  1. Your Rights

Under applicable data protection laws (including GDPR), you have the following rights regarding your personal data:

  • Right of access: You can request a copy of the personal data we hold about you.
  • Right to rectification: You can request that we correct inaccurate or incomplete data.
  • Right to erasure: You can request deletion of your data (subject to legal retention requirements).
  • Right to restrict processing: You can request that we limit how we use your data.
  • Right to data portability: You can request that we provide your data in a portable format.
  • Right to object: You can object to our processing of your data for legitimate interests.
  • Right to withdraw consent: If processing is based on your consent, you can withdraw it at any time.
  • Right to lodge a complaint: You can file a complaint with your local data protection authority.

To exercise any of these rights, please contact us at info@freyanco.com.

  1. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Secure SSL/TLS encryption for data transmission
  • Secure hosting with Hostinger
  • Limited access to personal data (only authorized personnel)
  • Regular security monitoring

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you use our Site at your own risk.

  1. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected:

  • Contact form data: Retained for as long as necessary to respond to your inquiry, typically 12 months unless a quote or contract requires longer retention or applicable law mandates longer retention.
  • Newsletter email: Retained until you unsubscribe.
  • Analytics data: Retained according to Google Analytics default settings (typically 26 months).
  • Transaction data (future e-commerce): Retained for as long as required by applicable tax and accounting laws, typically 7-10 years.
  • Blog comments (if enabled in future): Retained according to our moderation policy; you may request deletion at any time.
  1. Cookies and Similar Technologies

Our Site uses cookies and similar technologies. For detailed information about cookies used on our Site, their purposes, and your choices, please refer to our Cookie Policy.

  1. Third-Party Links

Our Site may contain links to third-party websites (social media, YouTube, etc.). We are not responsible for the privacy practices of these third-party sites. We encourage you to review their privacy policies before providing your personal data.

  1. Children’s Privacy

Our Site is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete such data and terminate the child’s account. If you believe we have collected data from a child under 13, please contact us at info@freyanco.com.

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any significant changes by posting the updated Privacy Policy on our Site and updating the “Last updated” date. Your continued use of the Site after such changes constitutes your acceptance of the updated Privacy Policy.

  1. Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about our privacy practices, please contact us:

COMPLEET IS SERVICES LTD
Suite 3, Floor 2
Valley Tower, Valley Road
Birkirkara, BKR 9022 – Malta

Email: info@freyanco.com
VAT Number: MT15147837
Registration Number: C23032

Data Protection Authority (Malta):
Office of the Commissioner for Data Protection
2, Airways House, High Street, Sliema SLM 1520 – Malta
Tel: +356 2328 7100
Email: commissioner@idpc.org.mt