Privacy Policy

Last updated: 1 April 2026

This Privacy Policy (also “Policy”) provides detailed information about the personal data processing practices followed by WIREWIT LTD, registry code: 16535657, registered address: 85 Great Portland Street, London, United Kingdom, W1W 7LT (also “Company,” “us,” or “we”), in connection with our website https://freshuis.com/ and the Services and Products offered through it. Here you will find information about the types of personal data being processed, respective purposes and legal bases, how personal data is protected, as well as other important information related to the processing of your personal data. Please review this document carefully to understand our practices related to personal data processing, when providing to you our Services and Products.

(1) Data Controller

The Company acts as the data controller, which means it decides how and why your personal data is processed. It also ensures that all data processing activities comply with applicable data protection laws, including the UK General Data Protection Regulation (GDPR), Data Protection Act 2018 (UK) and other applicable regulations. Where users are located in the European Union, the processing of personal data is also carried out in accordance with Regulation (EU) 2016/679 (EU GDPR). Nothing in this Policy limits the mandatory data protection rights granted under EU law.

(2) Contact Details of Your Data Controller

Name: WIREWIT LTD

Address: 85 Great Portland Street, London, United Kingdom, W1W 7LT

E-mail for communication: support@freshuis.com

(3) Data Collection Sources

We collect personal data from various sources, including direct interactions where you provide information, such as when creating an account or making purchases. Additionally, we collect data automatically through cookies and similar tracking technologies. We also obtain data from third-party service providers (e.g., payment processors), government authorities or regulators, and publicly available sources.

(4) Types of Data Collected

We may process the following categories of personal data:

User Account Data: including full name, passwords, account settings, activity logs, referral links, referral IDs, information about your workplace, your job role, etc.
Contact Information: including full name, email, phone number, address.
Identification Data: including full name, place of residence, date of birth, personal identification numbers, details of identification documents, etc.
Technical Data: including IP address, device type, browser details.
Transaction Data: including details on your orders, purchases, subscriptions and other transactions.
Payment Data: including payment and purchase history, payment card details, bank account details, etc. We (the Company) are not a payment institution or electronic money institution. All payment-related processing is carried out by licensed third-party payment providers. We do not store full payment credentials, such as card numbers. All financial data is transmitted and stored securely in compliance with UK data protection standards.
Marketing Data: including preferences and participation in marketing and loyalty programs.
User Generated and Uploaded Content: including any data, information and documents uploaded through your user account or otherwise shared with us or our services.
Compliance Data: including any information required for legal and regulatory compliance (e.g., in the field of anti-money laundering (AML), counter-terrorist financing (CFT), know-your-customer (KYC) and other similar processes).
User Support Data: including any information generated in the result of user support issues (e.g., type of technical issue occurred, resolution status, support agent engaged, etc.).

(5) Purposes and Legal Grounds for Processing

We utilize your personal data to ensure you receive the highest quality experience with our services. This includes processing your data for several purposes:

Account Management and Registration: We collect user account data, contact information, identification data, and user support data to establish and manage your account, giving you access to our services. This is necessary for the performance of our agreement with you.

Provision of Services: To deliver the services you request efficiently, we process contact information, transaction data, and any content you generate or upload, in line with our contractual obligations.

Identity Verification: To confirm your identity, residence, and secure your account against fraud or unauthorized access, we process compliance and identification data based on legal obligations and legitimate interests.

Order Fulfillment: Contact information and transaction data are used to process and complete your orders, ensuring efficient service delivery, as required to perform our contract with you.

Legal Compliance: To adhere to applicable laws, including AML, CFT, KYC, and other regulatory requirements, we process contact information, identification data, and user-generated content, fulfilling our legal obligations.

Transaction Management: Payment data is used to manage and facilitate secure, accurate, and compliant transactions, under the performance of our agreement.

Risk Management: Identification data, payment data, and user-generated content are processed to monitor and manage business risks, combining contractual performance, legal compliance, and legitimate interests.

Customer Communication: User account and support data are used to engage with you regarding your account, provide support, and address inquiries, in line with our contractual obligations.

Marketing: With your consent, and based on legitimate interests, we process user account data, identification, technical, and marketing data to send marketing communications and personalized content.

Fraud Prevention: Identification data, technical data, and payment data are processed to detect, prevent, and respond to fraud and unlawful activities, based on legal compliance and legitimate interests.

Security: To protect our systems and data, user account data, technical data, and support data are processed for contractual performance, legal obligations, and legitimate interests.

Technical Support: User account data, technical data, and support data are used to diagnose and resolve technical issues, ensuring service functionality, stability, and reliability.

Service Improvement: User account and support data are used to refine and enhance services based on feedback, behavior, and usage patterns, under contractual obligations and legitimate interests.

Dispute Resolution: User account, contact, identification, transaction, payment data, user-generated content, and support data are processed to manage and resolve legal claims or disputes, protecting our legal interests and complying with obligations.

(6) Recipients of Personal Data

We may share your personal data with trusted partners for the provision of our services, such as payment processors. Additionally, we may disclose your data to government authorities or regulators if required by law.

(7) Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact Information, Identification Data, Payment Data and Transaction Data) for a minimum of 6 years after they cease being customers for tax purposes.

Moreover, we keep data to ensure compliance with legal obligations, such as anti-money laundering (AML) regulations, for a period typically up to 5 years. Additionally, to protect our interests, we may retain data for the duration of the limitation period for claims against the Company, which is usually up to 10 years.

Once your personal data no longer serves any lawful purpose, we ensure it is securely deleted or anonymized to protect your privacy.

If you have consented to our use of your personal data, we will retain this until you withdraw consent.

(8) International Data Transfers

Your personal data may be transferred and processed outside the UK and/or European Economic Area (EEA) to our trusted services providers, including payment processors, cloud hosting providers, and compliance verification systems that carry out certain functions on our behalf and may operate or store data outside the United Kingdom and the European Economic Area (EEA).

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers, or we may use third party providers who are subject to the UK Extension to the EU-U.S. Data Privacy Framework (where applicable).

All third parties that receive personal data are carefully selected and bound by contract to process information only for the purposes described in this Privacy Policy. They are also bound by contract to maintain strict confidentiality and to apply suitably technical and organizational measures to safeguard your data.

(9) Essential and Optional Personal Data

Certain personal data is required for the functionality and availability of our Products. Failure to provide mandatory (essential) information may limit your access to some features. Optional information can be provided in line with your preferences, as well as managed via account settings. Whenever provision of data is mandatory, special marking will be added to make sure you are informed accordingly.

(10) Data Security

Ensuring the safety of your data is our utmost priority. We implement a variety of measures to protect your personal information, including:

Encryption: We utilize advanced encryption methods to safeguard your data during transmission and storage, preventing unauthorized access.
Access Controls: We enforce strict access controls, allowing only authorized personnel to access your data. These measures include multi-factor authentication and role-based access permissions.
Regular Training: Our team receives ongoing training on data protection and privacy best practices to ensure they understand their responsibilities and the importance of maintaining data security.
Security Audits: We perform regular security audits and assessments to identify and address any vulnerabilities in our systems and processes.
Data Minimization: We adhere to the principle of data minimization, collecting only the information necessary for our purposes and retaining it only as long as needed.
Incident Response: We have a comprehensive incident response plan in place to quickly address and mitigate any data breaches or security incidents that may occur.

You can further enhance the security of your data by following these steps:

Use Strong Passwords: Create unique and complex passwords for your accounts and update them regularly.
Enable Two-Factor Authentication (2FA): Add an extra layer of security by enabling 2FA wherever possible.
Be Vigilant: Stay alert to phishing attempts and avoid sharing your passwords or personal information with untrusted sources.
Keep Software Updated: Regularly update your devices and software to protect against security vulnerabilities.
Monitor Your Accounts: Regularly check your financial and online accounts for any suspicious activities and report any discrepancies immediately.
Use Secure Networks: Avoid using public Wi-Fi networks for sensitive transactions. If necessary, use a virtual private network (VPN) to secure your connection.
Install Security Software: Use reputable antivirus and anti-malware programs to protect your devices from malicious attacks.
Backup Your Data: Regularly back up important data to secure, separate locations to prevent loss in case of a breach or technical failure.
Be Cautious with Sharing Information: Limit the amount of personal information you share online, especially on social media and other public platforms.
Educate Yourself: Stay informed about the latest security threats and best practices for protecting your data.

(11) Data Subject Rights

You have the following rights regarding your personal data:

Access: You can request access to your data and obtain a copy of it.
Rectification: If your data is inaccurate or incomplete, you have the right to correct it.
Erasure: Under certain conditions, you may request the deletion of your data.
Restriction: You can request that we limit the processing of your data in specific situations.
Objection: You have the right to object to certain types of processing, such as direct marketing.
Portability: You can receive your data in a commonly used and machine-readable format and transfer it to another controller.
Withdrawal of Consent: If you have given consent for the processing of your data, you can withdraw it at any time.

Please note that these rights are not absolute and may be subject to legal preconditions. Additionally, to protect your privacy and security, we may need to verify your identity before processing your request.

To exercise any of these rights, please contact us using contact information provided in this Policy.

(12) Automated Decisions and Profiling

We do not engage in automated decision-making processes that have legal effects or significantly impact you. This means that any decisions regarding your personal data that could affect your legal rights or significantly influence your experience with us are always made by a human. However, we may use profiling techniques to enhance and personalize your experience. Profiling involves analyzing certain aspects of your personal data, such as your preferences, interests, and behavior, to offer you more relevant content and services. For example, this may include suggesting products or services that match your interests or customizing our communications to better suit your needs. We ensure that any profiling conducted is transparent, fair, and respects your privacy rights.

(13) Use of Cookies and Analytics Tools

Our website uses cookies and analytics tools to ensure stable operation, improve the user experience, and analyze how visitors interact with the platform. These tools allow us to remember your preferences, monitor performance, and identify potential issues in order to improve the website's functionality and security.

Where required by law, we obtain user consent for non-essential cookies (such as analytics or marketing tools) through a cookie consent mechanism displayed upon your first visit. You can manage or withdraw your preferences at any time through the platform settings.

You can manage or disable cookies in your browser settings at any time. However, keep in mind that certain features of the platform may not work correctly without them.

(14) Data of Minors

Our Services and Website are not intended for use by individuals under the age of 18 (the “Minor”). We do not knowingly collect, process, or store personal data from minors. In the event that we become aware of the inadvertent collection of personal data from a minor, we will take prompt and appropriate measures to delete such data from our records. If you are a parent or guardian and have reason to believe that your child under the age of 18 has provided us with personal data, we urge you to contact us immediately so that we can address the issue and ensure the removal of any such data from our systems.

By using our services and website, you represent and warrant that you are not a Minor as of the date of first access to our services and website.

(15) Complaints

If you have any complaints or concerns regarding how we handle your personal data, please do not hesitate to reach out to us. We value your feedback and are committed to addressing and resolving any issues promptly and to your satisfaction. Our team is dedicated to ensuring that your privacy rights are respected and that any concerns you have are thoroughly investigated and appropriately resolved.

However, if you feel that we have not adequately addressed your concerns, or if you prefer to report your complaint directly, you also have the right to file a complaint with your local data protection authority. In England, this is the Information Commissioner's Office (ICO).

The ICO's address:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

(16) Updates to This Policy

We may update this Policy periodically to reflect changes in our practices, legal requirements, or for regulatory reasons. We encourage you to revisit this Policy regularly to stay informed about how we are protecting your information. When we make significant changes to this Policy, we will communicate these changes in a clear and timely manner. This may include notifications on our website, direct emails, or other appropriate means of communication. By continuing to use our services after these changes have been posted, you agree to the updated terms of this Policy.

(16) Contact Information

For questions about the protection of personal data in our Company, as well as for the consideration of your complaint/submission, please contact us via support@freshuis.com.