FreeThinkingProject.org Privacy Policy

Effective from October 24, 2022

Welcome to FreeThinkingProject.org’s Privacy Policy

1. Please read carefully

FreeThinkingProject.org cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how FreeThinkingProject.org Ltd., together with its affiliated companies worldwide (“FreeThinkingProject”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all FreeThinkingProject users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all FreeThinkingProject services, including our websites (including www.FreeThinkingProject.org and any of its subdomains, the “Website”), web applications (“FreeThinkingProject Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services.

This policy describes our privacy practices – what Personal Information we collect about our Users, what we do with it, how we share it, and your rights regarding that Personal Information.

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By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy.

2. What ‘Personal Information’ do we collect?

2.1. User information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

1. Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., FreeThinkingProject’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).  
2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

2.2. Users of users ‘Personal Information’

We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.

3. Why do we collect such ‘Personal Information’

We use your Personal Information for the following purposes:

1. To provide and operate the Services;
2. .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
3. To provide our Users with ongoing customer assistance and technical support;
4. To be able to contact our Users with general or personalized service-related notices and promotional messages To help us to update, expand and analyze our records to identify new customers;
5. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
6. To analyze our performance and marketing activities;
7. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
8. To provide you with professional assistance , only upon your request;
9. To enhance our data security and fraud prevention capabilities; and
10. To comply with any applicable laws and regulations.

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We use your Personal Information for the purposes set out in Section 3 where:

1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);
2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of FreeThinkingProject by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

4. How we share your ‘Personal Information’

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

Third Party Service Providers:  FreeThinkingProject has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).

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FreeThinkingProject may share the following categories of Personal Information with Third Party Service Providers for a business purpose:

• identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
• commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered.

4.1.

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The Personal Information may be shared solely in accordance with this policy.

Law Enforcement, Legal Requests and Duties: FreeThinkingProject may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

4.2.

Protecting Rights and Safety:  FreeThinkingProject may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of FreeThinkingProject, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

4.3.

FreeThinkingProject Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with FreeThinkingProject.org Inc., our US-based subsidiary, in the course of facilitating and providing you (and your Users-of-Users) with our Services.

Sharing Personal Information by FreeThinkingProject subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with FreeThinkingProject’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.

4.4.

In connection with a change in corporate control: In addition, should FreeThinkingProject or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.

4.5.

Upon Your Further Direction: The FreeThinkingProject Services enable you, through different techniques, to engage and procure various third party services, products and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the FreeThinkingProject Website (including the FreeThinkingProject App Market), eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example:

a) Framed Pages: our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services  or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users.

b) App Market Developers: We allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the FreeThinkingProject App Market (“Third Party App(s)”) to Users, which you may integrate into your web or mobile sites. Each Third Party Developer is bound by the FreeThinkingProject App Market Partner Agreement, which among other things, restricts the ways in which such developers may access, store, share, and use the Personal Information you and/or your Users-of-Users provide to them.

c) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.

Please note that in the examples listed above in this Section 4.6, FreeThinkingProject merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, FreeThinkingProject acts as a service provider to you, disclosing information to the Third Party Services on your behalf. FreeThinkingProject will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.

FreeThinkingProject does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services.

4.6.

5. Where do we store your ‘Personal Information’?

Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the United States of America, Ireland and Israel. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

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FreeThinkingProject.org Ltd. is based in Israel, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.

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FreeThinkingProject affiliates and Third-Party Service Providers that store or process your Personal Information on FreeThinkingProject’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

5.1.

Transfer of EU Personal data : If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place.

5.2.

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In compliance with the Privacy Shield Principles, FreeThinkingProject.org commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: privacy@FreeThinkingProject.org. For the avoidance of doubt, FreeThinkingProject does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data.

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6. Users-of-users’ ‘Personal Information’

FreeThinkingProject may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with FreeThinkingProject, on the User’s behalf.

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 For such purposes, FreeThinkingProject serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.

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The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

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You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

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FreeThinkingProject cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

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For more information on how Users-of-Users Personal Information may be handled by FreeThinkingProject (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13.

If you are a visitor, user or customer of any of our Users, please read the following: FreeThinkingProject has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by FreeThinkingProject on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If FreeThinkingProject is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR).

7. Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in  order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

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Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

8. Communications from FreeThinkingProject

8.1. Promotional messages

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from FreeThinkingProject or our partners (acting on FreeThinkingProject’s behalf) through such means.

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If you do not wish to receive such promotional messages or calls, you may notify FreeThinkingProject at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

8.2. Service and billing messages

FreeThinkingProject may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

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It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a FreeThinkingProject User (which can be done by deactivating your account).

9. Your rights in relation to your ‘Personal Information’

FreeThinkingProject believes that it is imperative that all FreeThinkingProject users have control over their Personal Information. Therefore, depending on the way you use the FreeThinkingProject Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal Information to another service, restrict, or object to certain uses of your Personal Information (for example, for direct marketing purposes). Further, when we rely on your consent for processing of your Personal Information (for instance, for direct marketing) you can withdraw your consent at any time, and such withdrawal will take affect from thereon.

FreeThinkingProject will not charge you more if you exercise any of these rights and will continue to provide you with the same level of service.

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Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

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You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

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Please note that permanently deleting your FreeThinkingProject account erases all of your Personal Information from FreeThinkingProject's databases. After completing this process, you can no longer use any of your FreeThinkingProject Services, your account and all its data will be removed permanently, and FreeThinkingProject will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.

10.  Additional Information for California residents

If you are a California resident using the Services, the California Consumer Privacy Act ("CCPA") grants you the right to request access to and deletion of the Personal Information FreeThinkingProject collects about you, as well as to request that we disclose how we collect, use, and share your Personal Information.

California residents also have a right to opt-out of the sale of their Personal Information by a business and a right not to be discriminated against for exercising any of their rights under the CCPA.

No sale of Personal Information. FreeThinkingProject does NOT sell (as such term is defined in the CCPA) your Personal Information or your customers’ (Users-of-Users) Personal Information to third parties, and FreeThinkingProject has not sold Personal Information in the twelve months prior to the effective date of this Privacy Policy.

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No Discrimination. FreeThinkingProject does not discriminate against any User for exercising their rights under the CCPA.

California consumers can exercise their CCPA rights directly or through an authorized agent by signing in to their registered FreeThinkingProject account at FreeThinkingProject.org and following the instructions outlined below. Please note: in order to protect Users’ accounts and Personal Information and safeguard Users’ privacy rights, we verify Users’ deletion and access requests, and to that extent, we may ask you for additional information or documentation (depending on the case), such as account related information, and, in some cases, billing information used to purchase paid Services, and a copy of documents that can assist with verifying your identity.

Such identification documentation (if requested) will be used only for verification purposes and we will delete it after your request is processed.

The following instructions apply to Personal Information we may collect from California residents on or through our Services.

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Once we receive and verify your consumer request, we will delete your personal information from our records unless an exception applies. We will make reasonable efforts to honor your request promptly and consistent with requirements under applicable law.

Please note that permanently deleting your FreeThinkingProject account erases all of your Personal Information from FreeThinkingProject's databases. After completing this process, you can no longer use any of your FreeThinkingProject Services, your account, and all its data will be removed permanently, and FreeThinkingProject will not be able to restore your account or retrieve your data in the future. Additionally, if you contact our support channels in the future, the system will not recognize your account, and support agents will not be able to locate the deleted account.

11. Questions and complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

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Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.  

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You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

12. Data retention

We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.

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We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

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We maintain a data retention policy which we apply to Personal Information in our care.

13. Security

FreeThinkingProject has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

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Regardless of the measures and efforts taken by FreeThinkingProject, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with FreeThinkingProject or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.

Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.

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14. Third-party websites

Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third party websites and services.

15. Public forums and user content

Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.

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In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.

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If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.

We have put adequate security measures in place to protect your Personal Information.  However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.

16. Updates and interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (using one of the notification methods set forth in Section 15.3 of the Terms of Use) prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, FreeThinkingProject Apps, Mobile Apps and other Services.

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Any heading, caption or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

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This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your FreeThinkingProject Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.