Skip to content

Legal

What we collect, why we collect it, and what you can ask us to do about it.

Draft, not yet reviewed by counsel

This document is a structured starting point, not legal advice and not a binding policy. It must be reviewed by a qualified solicitor, and every bracketed placeholder completed, before the site goes live. Search the source for TODO_LEGAL.

Last updated 7 August 2026 · Version 0.2 (draft)

01

Who we are

Valorifi is a trading name of Freedom Labs Ltd. (“Freedom Labs”, “we”, “us”), an engineering consultancy incorporated in the British Virgin Islands. Freedom Labs is the same practice that builds Freed Finance.

Freedom Labs is the data controller for personal data collected through this website. You can reach us about anything in this notice at info@freed.finance, and we answer within one working day.

02

Which law applies

Our home regime is the Data Protection Act, 2021 of the Virgin Islands, supervised by the Office of the Information Commissioner.

Because we offer services to people in the United Kingdom and the European Economic Area, the UK GDPR and the EU GDPR also apply to that processing under Article 3(2), even though we are not established in either. Where they apply, we honour the rights they give you in full, and they are set out in section 08 below.

Whichever of those applies to you, the contact point for exercising a right or raising a concern is the same: info@freed.finance.

03

What we collect

Information you send us. If you contact us by email, or by submitting a brief through this site, we receive your name, email address, an optional phone number and link, and whatever you choose to tell us about your organisation and the work you are considering. You may also attach a file.

Email list. If you request the one-pager we keep your address so we can send you our writing. That is a separate consent from being contacted commercially, and requesting a document is not treated as permission to sell to you. Every email carries a one-click unsubscribe.

Technical information. Our hosting provider records standard server logs, which may include IP address, browser type and pages requested. These are used to operate and secure the service.

We do not use advertising trackers, sell personal data, or build behavioural profiles. This site sets no cookies at all. It stores two version strings in your browser so that a dismissed announcement stays dismissed; neither identifies you. See /cookies.

04

Why we process it, and on what basis

To respond to enquiries. Legitimate interests, and steps taken at your request before entering a contract.

To deliver engagements. Performance of a contract.

To keep the service secure and available. Legitimate interests in protecting our systems.

To meet legal and regulatory obligations. Legal obligation.

05

Confidentiality

We treat the content of enquiries as confidential from the first message, whether or not a non-disclosure agreement has been signed. Information about a prospective engagement is shared internally only with those who need it to respond.

Do not send credentials, private keys or production secrets through this site or by email. If you do, we will tell you and ask you to rotate them.

06

Who we share it with

We use three processors to run this site, and no others:

Vercel Inc. hosts the site and produces the server logs described above. Resend delivers the email generated when you submit the enquiry form or request the one-pager. Supabase stores the email address of anyone who asks to hear from us, so that the list can be maintained and unsubscribes honoured.

Each is bound by a data processing agreement and may act only on our instructions. There is no analytics provider, no advertising network, no chat widget and no third-party script on this site.

We do not share personal data with anyone else except where required by law or on your explicit instruction.

07

International transfers

We are incorporated in the British Virgin Islands and both of our processors are established in the United States, so personal data you send us leaves the United Kingdom and the European Economic Area.

Where UK or EU GDPR applies to that transfer, we rely on the Standard Contractual Clauses, together with the UK International Data Transfer Addendum for United Kingdom data, as incorporated into our agreements with each processor. A copy of the relevant terms is available on request at info@freed.finance.

08

Your rights

You have the right to ask for a copy of the personal data we hold about you, to have it corrected or erased, to restrict or object to how we use it, and to receive it in a portable format. Where we rely on legitimate interests, you may object at any time.

To exercise any of these, write to info@freed.finance. We will respond within one month. We do not charge for this.

If you are not satisfied with our response you may complain to the Office of the Information Commissioner of the Virgin Islands, to the Information Commissioner’s Office at ico.org.uk if you are in the United Kingdom, or to your local supervisory authority if you are in the European Economic Area.

09

How long we keep it

Enquiries that do not lead to an engagement: 24 months from the last contact, then deleted.

Engagement records: for the duration of the engagement and 7 years afterwards, to meet contractual, tax and professional obligations.

Server logs: as retained by our hosting provider under its own policy, which is currently 30 days.

Email list: until you unsubscribe, and then indefinitely as a suppression record so that a later import cannot add you back. That record holds your address and the fact that you opted out, nothing else. Ask and we will erase it outright.

Files you attach to an enquiry are checked and held in memory only. They are forwarded with the email and never written to our disk.

10

Security

We apply technical and organisational measures appropriate to the sensitivity of the data we hold, including encryption in transit, access control on a need-to-know basis, and logging of access to client material. No system is perfectly secure, and we do not claim otherwise.

11

Changes

We will post any material change to this notice on this page and update the date above. Where the change affects how we use data you have already given us, we will tell you directly.

12

Contact

Questions about this notice, or to exercise any right above: info@freed.finance. General enquiries: use the form at /contact.