Privacy Policy (GDPR)

Effective date: 14 December 2025

1. Controller

Freeys
Spaces – Eindhoven, South Building
Schimmelt 2–16
5611 ZX Eindhoven
The Netherlands
privacy@freeys.com

Freeys provides an AI-powered HR assistant operating via WhatsApp. When Freeys is used within an organization, the employer is usually the data controller, and Freeys acts as a data processor under Article 28 GDPR.

2. Personal data processed

• WhatsApp phone number and user identifiers
• Message content exchanged with the HR assistant
• Message metadata (timestamps, delivery status)
• Organization context (employer, language, policy version)
• Security and operational logs

3. Special categories of data

HR conversations may include special categories of personal data (Article 9 GDPR), such as health-related leave or benefits. Users should avoid sharing unnecessary sensitive information.

4. Purposes of processing

• Answering HR-related questions via WhatsApp
• Routing conversations to the correct organization
• Ensuring service security, reliability, and compliance
• Generating responses using an AI assistant

5. Legal basis

• Performance of a contract (Article 6(1)(b))
• Legitimate interests (Article 6(1)(f))
• Employer legal obligations under employment law
• Consent where required (Article 6(1)(a))

6. AI processing (OpenAI)

Freeys uses an AI assistant powered by OpenAI. Relevant parts of user messages are sent to OpenAI solely to generate responses.

• Data minimization is applied
• No automated decision-making with legal effect
• User messages are not used by Freeys to train AI models

7. Recipients

• WhatsApp / Meta (message delivery)
• OpenAI (AI response generation)
• Hosting and monitoring providers
• Employer administrators (if configured)

8. International transfers

Where data is processed outside the EU/EEA, Freeys relies on appropriate safeguards such as Standard Contractual Clauses.

9. Retention

Personal data is retained only as long as necessary. Default chat retention is limited (typically 30–180 days), unless configured otherwise by the employer or required by law.

10. Your rights

• Access, rectification, erasure
• Restriction and objection
• Data portability

Requests can be submitted via privacy@freeys.com or our Data Deletion page.

11. Complaints

You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).