PRIVACY NOTICE
Last updated 09.15.2025

Thank you for choosing to be part of our community at FRDM Inc. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at hello@frdm.co. When you use any of our services (the "Services," which include using our software to map your supply chain, uploading spend data, receiving alerts, trading partners, etc), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. This privacy notice applies to all information collected through our Services as well as any related services, sales, marketing or events. Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us. We collect information that you provide to us.​ We collect personal information that you voluntarily provide to us when you register with FRDM or request a demo from our website and when you express an interest in obtaining information about us or our products and Services, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us, the choices you make, and the products and features you use. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Information automatically collected. Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our site. We automatically collect certain information when you visit, use, or navigate to the FRDM website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our services, and other technical information. This information is primarily needed to maintain the security and operation of our database, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?​
In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis:​Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in a business transfer. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
​In Short:  We may use cookies and other tracking technologies to collect and store your information for essential website functionality, analytics, and improving your user experience.​We use cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to access or store information when you visit our website or use our services. These technologies help us maintain your login sessions and preferences, analyze website traffic and usage patterns, improve our services and user experience, and ensure the security and proper functioning of our platform. You can manage cookies through your browser settings to block, delete, or receive alerts about cookies. For more detailed information about the specific cookies we use, their purposes, and how to manage them, please contact us at hello@frdm.co.

4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? ​
In Short:  We may transfer, store, and process your information in countries other than your own.​ Our servers are located in the United States and Australia. If you are accessing our software from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in other countries. If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

5. HOW LONG DO WE KEEP YOUR INFORMATION?
​In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.​We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than 30 days. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. DO WE COLLECT INFORMATION FROM MINORS?​
In Short:  We do not knowingly collect or solicit data from or market to children under 18 years of age.​ By using the FRDM software, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor’s use of the software. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@frdm.co.

7. WHAT ARE YOUR PRIVACY RIGHTS?
You may review, change, or terminate your account at any time.​ If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. Account Information​: If you would at any time like to review or change the information in your account or terminate your account, you can update it within the application settings. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt out, you may send us an email asking to be removed.

8. CONTROLS FOR DO-NOT-TRACK FEATURES​
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
Yes, California residents have enhanced privacy rights under both the California Consumer Privacy Act (CCPA) and California Civil Code Section 1798.83, known as the “Shine The Light” law. If you are a California resident, you may exercise the following rights regarding your personal information: Right to Know - you can request information about what personal information we collect, use, disclose, and sell, including the categories of information, sources, business purposes, and third parties involved; Right to Delete - you can request deletion of your personal information, subject to certain legal exceptions; Right to Opt-Out - you can opt out of the sale of your personal information (we do not currently sell personal information); and Right to Non-Discrimination - we cannot deny services, charge different prices, or provide different service quality for exercising your privacy rights. To submit a CCPA request, contact us at hello@frdm.co and include your name, account email, confirmation of California residency, and details about which right you wish to exercise. We will verify your identity and respond within 45 days. Under the “Shine The Light” law, you may also annually request free information about personal information categories we shared with third parties for direct marketing purposes in the previous year, including the names and addresses of those third parties. Please note that while we will delete your personal information from active systems upon request, complete removal from backup systems may not be immediate due to technical constraints and legal retention requirements.

10. WHAT MEASURES DO WE TAKE FOR SECURE DATA STORAGE AND MANAGEMENT?
Recognizing the importance of your data's security, we have engaged with leading third-party vendors for enhanced cloud data storage solutions. Specifically, we utilize the services of Amazon Web Services (AWS) and Fly.io, both of which are renowned for their rigorous security protocols and commitment to data privacy. These collaborations enable us to leverage advanced technology for the secure storage and careful management of your information. AWS and Fly.io are dedicated to adhering to the highest data security standards, reinforcing our commitment to safeguarding your privacy. By integrating these reliable platforms, we fortify our infrastructure against threats and ensure compliance with prevailing data protection laws.

11. DO WE MAKE UPDATES TO THIS NOTICE?​
Yes, we will update this notice as necessary to stay compliant with relevant laws.​ We reserve the right to update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and it will be effective as soon as it becomes accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at  hello@frdm.co. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?​ Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by emailing us at hello@frdm.co. We will respond to your request within 30 days.

‍