Privacy Policy

1. Who we are

FREELVY, a French SAS registered with the Paris Trade and Companies Register under SIREN 106 293 541, with its registered office at 47 rue Vivienne, 75002 Paris, is the controller for the processing described in sections 2, 3 and 4 below. Full identification details are in our Legal Notice.

For the data our customers import into their own workspace, their CRM records, their own lists, the content of their campaigns, the customer is the controller and Freelvy acts as a processor on their instructions, under a data processing agreement.

2. Customer and visitor data

Account data

Name, professional email, organisation, role. Legal basis: performance of the contract.

Usage data

Searches run, credits consumed, features used, technical logs. Legal basis: legitimate interest in operating and securing the service.

Billing data

Plan, invoices, payment status. Card details are handled by our payment provider and never stored by us. Legal basis: contract and legal accounting obligations.

Support and marketing

Messages you send us and, where you have asked for them, product emails. Legal basis: legitimate interest and, for marketing to non-customers, consent where required.

3. Business contact data in our results

This section concerns people who are not our customers, but whose professional information appears in results produced by Freelvy. It is the information required by Article 14 of the GDPR, which applies when personal data has not been collected from the person directly.

Categories of data

Professional identity (name, job title, employer), professional contact details (business email, direct line), public professional profile, and company-level attributes such as headcount, technologies or funding.

Sources

Publicly accessible sources on the open web, official company registries, professional networks and job boards, and licensed third-party data providers. On request we will tell you the specific source of the record concerning you.

Purpose

Allowing our business customers to identify and contact other businesses in a professional capacity. We do not build profiles of private individuals and we do not process data about you outside your professional life.

Legal basis

Legitimate interest (Article 6.1.f GDPR) in business-to-business prospecting. We have carried out and documented a balancing test, and we do not rely on this basis for special categories of data, which we do not process.

Retention

Records are kept while they remain accurate and useful, and are re-verified periodically. A record that has been objected to is not deleted outright: it is placed on a permanent suppression list so it cannot be re-sourced later.

You can object at any time. For prospecting, the right to object under Article 21.2 of the GDPR is absolute: we do not weigh it against our interest, we act on it. Use the Opt-out & Privacy Request page.

4. Emails sent through Freelvy

Campaign emails are sent from our customer's own mailbox, not from ours. For those messages the customer is the sender and the controller. Freelvy provides the tooling, enforces do-not-contact lists across all workspaces, and requires an unsubscribe route in every sequence. If you received a message you did not want, you can reply to the sender directly, or use our opt-out page and we will suppress your record for every customer at once.

5. Who we share data with

We do not sell personal data. We share it only with the categories of recipients below, each bound by a written processing agreement and limited to what their task requires:

• Infrastructure and hosting providers, to run the service.
• Data and enrichment providers, to source and verify professional contact details.
• AI model providers, to run the agent and generate campaign copy.
• Email delivery and deliverability providers.
• Payment and invoicing providers.
• Support and analytics tooling.
• Public authorities, where a legal obligation requires it.

An up-to-date list of our subprocessors, naming each company and its location, is available on request at contact@freelvy.com and is annexed to the data processing agreement signed with our customers.

6. Transfers outside the EEA

Freelvy is operated from France. Where a provider processes data outside the European Economic Area, the transfer is covered by the European Commission's Standard Contractual Clauses, or by an adequacy decision where one applies, together with the supplementary measures the transfer impact assessment identifies. A copy of the safeguards in place can be requested at contact@freelvy.com.

7. Your rights

Under the GDPR you have the right of access, rectification, erasure, restriction, portability, and objection, including the absolute right to object to prospecting described in section 3. You can also give instructions about the fate of your data after your death, under Article 85 of the French Data Protection Act.

Write to contact@freelvy.com or use the opt-out page. We answer within one month of receipt, extendable by two months for complex requests, in which case we tell you within the first month. We may ask you to prove your identity before acting, which protects you against someone impersonating you.

If you consider that your rights have not been respected, you may lodge a complaint with the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or cnil.fr, or with the supervisory authority of the country where you live.

8. Security

Data is encrypted in transit and at rest, access is restricted to the staff who need it, and credentials to your own mailbox or CRM are stored encrypted and used only to carry out the actions you have configured. In the event of a personal data breach likely to result in a risk to your rights, we notify the CNIL within 72 hours and inform the people concerned without undue delay where the risk is high.

9. Cookies

This website uses only the cookies strictly necessary to serve the site. If we later add audience measurement or advertising cookies, we will ask for your consent through a banner that makes refusing as simple as accepting, and this policy will be updated first.

10. Changes

We update this policy when our processing changes. The date below tells you which version is in force; material changes are communicated to customers by email before they take effect.

Last updated: 4 August 2026.