Privacy Policy

Last updated: January 22, 2026
Thank you for taking the time to read our privacy policy. At Freckle.io, Inc. ("Freckle", "we", "us", or "our"), your privacy is of the utmost importance. We want you to be fully informed about the information we collect, how it is used, disclosed, and protected, and the choices you have with it.Freckle provides AI-powered CRM enrichment services that help businesses find and enrich company and contact data across the web and multiple data providers through natural language inputs (collectively, our "Services"). This privacy policy sets out how we collect, use, process, store, and disclose personal information in providing the Services and on https://freckle.io (the "Website").
1. PERSONAL INFORMATION WE COLLECT
Customer Information
In order to serve our Customers, Freckle will collect various information on our Customers, including:
  • Employee information including your name, company email, company name, company website URL.
  • Account information including username and password.
  • Correspondence, which may include any personal information provided during an email correspondence or customer service engagement.
  • Billing and administrative finance information.
  • Customer Data uploaded or transmitted through communications or use of our Services, including CRM data, contact information, company data, and enrichment requests.
  • Information about how our Customers use our Website and Services, including time spent on our applications, behavioral activity, and metadata associated with software interactions.
  • Metadata and analytics for your use of our Website and Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages.
  • We may use cookies, beacons, pixel tags, and other similar technologies to collect additional information automatically as you interact with the Website and Services and to personalize your experience with our Website and Services.
  • When you interact with our brand or community forums on a social media platform, we may collect certain information that you or the platform make available to us such as Website metadata analytics, your social media account ID, your social media 'likes', click-throughs to our Website, or custom interactions.
AI and Data Processing Information
‍As part of our AI-powered enrichment services, we collect and process:
  • Natural language queries and prompts submitted to our AI systems.
  • Data retrieved from third-party sources in response to enrichment requests.
  • Metadata about AI processing activities, including model interactions and response quality metrics.
  • Training data derived from aggregate, anonymized usage patterns to improve our AI models (no individual-level training without explicit consent).
2. HOW WE USE PERSONAL INFORMATION
Subject to the terms of our Customer agreements, we may use personal information for the following purposes:
  • To provide our Website and Services, including AI-powered data enrichment and CRM integration.
  • Customer support, including email and chat.
  • To process payments securely.
  • To improve our Website, Services, and AI models through aggregate analysis.
  • To send our Customers marketing and promotional communications in accordance with individual marketing preferences.
  • To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.
  • To ensure our Services are serving their intended purposes and for product improvements.
  • For any legal purpose necessary, including IP protection, or if Freckle is required to process information as a result of a court order or other legal or regulatory proceeding.
3. HOW WE DISCLOSE PERSONAL INFORMATION
Third-Party Service Providers
We may disclose information with select vendors in order to utilize:
  • Customer support systems and email service providers.
  • Customer relationship management systems.
  • Analytics and website optimization services.
  • Cloud infrastructure providers (Amazon Web Services, Google Cloud Platform).
AI Model Providers
‍Our Services integrate with third-party AI model providers to deliver enrichment capabilities. When you use our AI-powered features, limited data may be shared with:
  • OpenAI (GPT models) - subject to OpenAI's data usage policies.
  • Anthropic (Claude models) - subject to Anthropic's data usage policies.
  • Other AI providers as disclosed in our service documentation.
IWe configure our AI provider relationships to prohibit the use of your data for training their models. Customer Data is processed solely to provide enrichment services and is not retained by AI providers beyond what is necessary for service delivery.
Data Enrichment Sources
To provide our enrichment services, we access and process data from over 40 third-party data providers. These providers supply publicly available business information, contact data, and company intelligence. We maintain data processing agreements with all enrichment data providers.
Other Disclosures
In addition, we may disclose information in order to:
  • Protect the legal rights of our company, our employees, our agents, and our affiliates.
  • Protect the safety and security of those who access and use our Services.
  • Detect and protect against fraud.
  • Comply with law or legal process.
  • Complete a legal transaction related to the sale of our business or any assets.
Freckle may disclose aggregate or anonymous information for any purpose. This means that the information we disclose does not identify specific individuals, nor is it combined with other data to protect your privacy.
4. PRIVACY CHOICES
We provide you with the following choices with our use of your personal information:
  • Access the personal information we maintain about you.
  • Delete the personal information we maintain about you.
  • Correct inaccurate personal information we maintain about you.
  • Opt out of certain uses of your personal information, notably marketing emails and cookie-based advertising.
  • Obtain a copy of your personal information in a portable format.
  • Object to automated decision-making or profiling activities.
You can exercise these rights by contacting us at privacy@freckle.io.
For Customer Employees: If you are a current or former employee of one of our Customers, and you would like to fulfill your rights to the personal information we maintain about you on behalf of our Customer, please contact a representative of that Customer rather than email us with your request. We cannot provide personal information about a specific individual on behalf of a Customer without their express written instructions.
5. COOKIES AND OTHER TRACKING TECHNOLOGIES
Like many companies, we use cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect information about your browsing activities, your interactions with websites and our Services, and to serve tailored ads and for the purposes described in this Privacy Policy.

There are a number of ways to opt out of having your online activity and device data collected through these services:
  • Blocking Cookies In Your Browser: Most browsers let you remove or reject cookies. For more information, visit www.allaboutcookies.org.
  • Advertising Industry Opt-Out Tools: Visit http://optout.aboutads.info for U.S. residents or https://www.youronlinechoices.eu/ for EU/UK residents.
Do Not Track: We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
6. SECURITY
We maintain industry-standard safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control, including:
  • Encryption of data in transit using TLS/SSL protocols.
  • Encryption of sensitive data at rest.
  • Multi-factor authentication for system access.
  • Regular security assessments and vulnerability testing.
  • Employee security training and background checks.
  • Compliance with SOC 2 Type II standards (certification available upon request).
Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure.
7. RETENTION
We will retain your information for as long as your customer account or inquiry is active or as needed to provide you with the Website or any requested services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information.
8. U.S. STATE-SPECIFIC NOTICE
Multiple U.S. states have enacted comprehensive privacy laws. The following state laws may apply: California Consumer Privacy Act (CCPA/CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA), Oregon Consumer Privacy Act (OCPA), Texas Data Privacy and Security Act (TXDPSA), Montana Consumer Data Privacy Act (MTCDPA), Iowa Consumer Data Protection Act (IACDPA), Delaware Personal Data Privacy Act (DEPDPA), Nebraska Data Privacy Act (NEDPA), New Hampshire Privacy Act (NHPA), New Jersey Data Privacy Act (NJDPA), Tennessee Information Protection Act (TNIPA), Minnesota Consumer Data Privacy Act (MNCDPA), Maryland Online Data Privacy Act (MDODPA), Indiana Consumer Data Protection Act (INCDPA), Kentucky Consumer Data Protection Act (KYCDPA), and Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA).
Additional Privacy Rights
If you are a resident of the above states, you may have the right to:
  • Opt out of the 'sale' or 'share' of your personal information for targeted advertising: We do not 'sell' or 'share' your personal information for monetary benefit. However, some third party cookies placed on our Website may be considered a 'sale' or 'share' under these privacy laws. You may opt out of such cookies as detailed in the 'Cookies and Tracking Technologies' section above.
  • Opt out of automated decision-making and profiling: If we engage in automated decision-making that produces legal or similarly significant effects, you have the right to opt out. Currently, our AI enrichment services do not make automated decisions with legal or similarly significant effects on individuals.
  • Limit the use of sensitive personal information: You may limit our use of sensitive personal information to only what is necessary to provide our services.
You can exercise these rights by emailing us at privacy@freckle.io.
Appeal Rights
If we deny your privacy request, you may appeal that decision by emailing us at privacy@freckle.io within 30 days of receiving our decision. We will respond to your appeal within 45 days. If you are still unsatisfied with our response, you may have the right to file a complaint with your state attorney general.
Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights, including by denying services, charging different prices, or providing a different level of service quality.
9. EEA/UK NOTICE
The European Economic Area ("EEA") and the United Kingdom ("UK") have each enacted privacy laws. The European Union's ("EU") and the UK's General Data Protection Regulation (collectively, the "GDPR") create additional privacy obligations for 'Controllers' of personal data and provide EU and UK residents with additional privacy rights.
Legal Basis
Under the GDPR, we process personal data under the following legal bases:
  • Contract Fulfillment: Providing Services, payment processing, customer support.
  • Legitimate Interest: Service improvements, fraud prevention, marketing communications.
  • Consent: Cookie placement, optional marketing communications.
  • Legal Obligation: Compliance with applicable laws and regulations.
Controller Designation
In providing our Website and Services, Freckle operates as a 'Controller' for Customer account data and as a 'Processor' for Customer Data processed through our Services.
Cross-Border Data Transfers
If you are a resident of the EEA, UK, or Switzerland, we may transfer to, and store the data we collect about you, to countries other than the country in which the data was originally collected, including the United States. Those countries may not have equivalent data protection laws as the country in which you provided the data.

When we transfer your data to other countries, we protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA, UK, and Switzerland. We rely on Standard Contractual Clauses ("SCCs") for the transfer of personal data to countries that have not received an applicable adequacy decision, as well as the UK's 'International Data Transfer Addendum' to the SCCs.

For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at privacy@freckle.io.
Additional Rights for UK or EEA Residents
In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
10. AI-SPECIFIC DISCLOSURES
How We Use AI
Our Services use artificial intelligence and machine learning technologies to:
  • Process natural language queries to identify and retrieve relevant data.
  • Enrich CRM records with data from multiple sources.
  • Match and deduplicate company and contact information.
  • Analyze data quality and suggest improvements.
AI Training and Your Data
Customer Data is not used to train AI models. We do not use your uploaded Customer Data, enrichment queries, or results to train our AI models or those of our AI provider partners. Our agreements with AI providers specifically prohibit the use of your data for model training purposes.

We may use aggregate, anonymized usage statistics and performance metrics to improve our Services, but such data cannot be linked back to individual customers or users.
Automated Decision-Making
Our AI systems assist in data enrichment and matching but do not make automated decisions with legal or similarly significant effects concerning individuals. All enrichment results are provided as recommendations that require human review and decision-making.
AI Model Accuracy and Limitations
While we strive for high accuracy in our AI-powered enrichment services, AI models may occasionally produce incomplete or inaccurate results. We encourage customers to:
  • Review and verify enrichment results before using them for business decisions.
  • Report any quality issues or inaccuracies to our support team.
  • Understand that AI-generated content may contain errors or biases inherent in the underlying data sources.
11. CHILDREN'S PRIVACY
We do not intentionally collect any personal information from children under the age of 16. If you believe we have obtained personal information associated with children under the age of 16, please contact us at privacy@freckle.io and we will delete it.
12. THIRD-PARTY LINKS
The Website and Services may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of any other site that collects personally identifiable information.
13. DATA BREACH NOTIFICATION
In the event of a data breach that affects your personal information, we will notify affected individuals and applicable regulatory authorities in accordance with applicable data protection laws, typically within 72 hours of discovering the breach. Our notification will include:
  • A description of the nature of the breach.
  • The categories and approximate number of individuals affected.
  • The likely consequences of the breach.
  • Measures taken or proposed to address the breach and mitigate harm.
  • Contact information for further inquiries.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time as we update or expand our Website and/or Services. If we make material changes, we will post the updated Privacy Policy on this page with a 'Last Updated' effective date of the revisions. For material changes, we will provide at least 30 days' notice through email or prominent notice on our Website. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Website or Services.
15. CONTACT US
If you have any questions about our privacy or security practices, or if you are a Freckle Customer and would like to request access to or correction of your personal information, you can contact us at privacy@freckle.io.