Survey Privacy Notice

1. Who we are

This survey is run by Freetrade Limited, 145 City Road, London EC1V 1AZ, registered in England and Wales (company number 09797821) and authorised and regulated by the Financial Conduct Authority (FRN 783189). We are the controller for the personal data described here. You can reach our Privacy team at privacy@freetrade.io.

2. What this notice covers

It explains how we handle your personal data when you take part in this product research survey and, if you choose, the associated prize draw. It sits alongside, and should be read in conjunction with, our standard Privacy Policy (freetrade.io/legal/privacy-policy).

3. The data we collect

Your survey responses; a unique identifier carried by your invitation link, which connects your responses to your Freetrade account; the email address linked to your Freetrade account, but only if you opt into the prize draw; and information already held on your Freetrade account (such as account types and product usage), which we combine with your responses for analysis.

4. How and why we use your data

We use your responses, combined with your account information, to understand customer needs and inform the design of future products and services. Our lawful basis is our legitimate interests in conducting market research to improve our offering; you have the right to object at any time (see Your rights). When you provide your email address to enter into the prize draw, we use your account-linked email to administer the draw and, for winners, to deliver the prize; our lawful basis for sharing a winner's email with Amazon EU S.à r.l., the issuer of Amazon.co.uk gift cards is your consent, which you give by opting in and can withdraw before the closing date.

5. Combining your answers with your account data

So the research is meaningful, we match your responses to information from your Freetrade account. This applies to all responses, whether or not you enter the prize draw. The matching is internal and used only for research analysis: raw, identifiable responses are only accessible to our research team, and everyone else sees aggregated results. It does not feed automated decisions about you, it is never used for marketing or to target you with promotions, and it does not affect your account, pricing, or the service you receive.

6. Who we share data with

Your responses are collected through our survey provider, Typeform, acting as our processor under a data processing agreement; where this involves any transfer outside the UK, appropriate safeguards are in place. To select prize draw winners we use an independent certified random-number service (randomdraws.com); we do not send it any personal data — winners are identified by matching random numbers to entries internally. For winners only, we share the email address you provided with Amazon EU S.à r.l., the issuer of Amazon.co.uk gift cards, which emails the gift card code to you directly. Amazon processes your email address as an independent controller under its own privacy notice (amazon.co.uk/privacy); we share only your email address and nothing about the survey or your responses. For winners only, we also make the winner's surname and county available to anyone who requests them within one month of the draw closing, as the CAP Code requires, and we may provide winner details to the Advertising Standards Authority; winners can object to the on-request disclosure by contacting us at privacy@freetrade.io.

7. International transfers

Amazon EU S.à r.l. is established in Luxembourg. This disclosure is covered by the UK's adequacy regulations for the EEA, so no additional transfer safeguard is required.

8. How long we keep your data

We keep survey responses and the matched analysis dataset for no longer than necessary for the research, and in any event no more than 12 months from the close of the survey, after which they are deleted or retained in aggregated, non-identifiable form only. If you opt into the draw, we keep your email for draw administration only: winners' emails retained for these purposes will deleted within 90 days of confirmed gift-card delivery, and all other entries within 90 days of the draw date, unless we need to retain limited records to meet a legal or regulatory obligation.

9. Your rights

You have the right to access your data, to have it corrected or erased, to restrict or object to processing, and to data portability, in each case as the law allows. Because our research relies on legitimate interests, you can object at any time by contacting privacy@freetrade.io — if you do, we will exclude your responses from further analysis and remove the link to your account. Where we rely on your consent (sharing a winner's email with Amazon), you can withdraw it before the closing date by contacting privacy@freetrade.io, though we cannot enter you into the draw without it. If you are unhappy with how we have handled your personal data, you can complain to us at privacy@freetrade.io and we will look into it. You can also complain to the Information Commissioner's Office (ico.org.uk).

10. Taking part is voluntary

Completing the survey and entering the prize draw are both optional, and the survey is only for research purposes (not marketing) and taking part will not sign you up to any marketing from Freetrade, and your answers in the survey will have no effect on your Freetrade account or the service you receive from Freetrade.