Privacy Policy

Who we are

Policy effective as of: 19/08/2019

1. Introduction

Thank you for visiting  (Our Site). This privacy policy (Privacy Policy) sets out the ways in which we, Freebie Freedom (weusour), collect and process your personal information in connection with our services.

This Privacy Policy also explains what rights you have in connection with your personal information, including the right to withdraw your consent, object to our processing your personal information and/or unsubscribe from our marketing communications. For more detail on your rights, please see paragraphs 8 and 9 of this Privacy Policy.

2. About Us

2.1 Freebie Freedom is the trading name of Stratosphera Limited, a company registered in England and Wales under company number 11179655.

2.2 Stratosphera Limited is the data controller of the personal information that we process on Our Site and via our services. You can contact us:

In writing:

Stratosphera Ltd,

The OpTIC Technology Centre
Ffordd William Morgan
St Asaph Business Park
St Asaph
LL17 0JD;

By email:  (please include “Personal Data Request” in your subject heading)

3. What personal data we collect and why we collect it

3.1 Depending on how you use Our Site, we will collect certain information about you. We collect and process more personal information about those who subscribe to receive our marketing communications, than those who simply visit Our Site without subscribing.

3.2 When you visit Our Site (and regardless of whether you subscribe to receive our marketing communications), we will collect certain information about how you use Our Site and the device that you use to access it. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to Our Site, number of page views, offers you click on and/or complete (including on third party sites), how you navigate through Our Site, the search queries you make and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected by third parties (such as Facebook, Google and Bing) using cookies. For more information about cookies and what you can do to disable certain cookies on Our Site, please see the Cookie Policy.

3.3 If you subscribe to receive our marketing emails (whether via us or via a third party), we may collect:

3.3.1 your email address;

3.3.2 your gender (if you decide to provide this on request);

3.3.3 your IP address and any other information we have collected about your visit to Our Site (see paragraph 3.2 above);

3.3.4 your name (if you have provided this to a third party website and agreed that this can be provided to us);

3.3.5 any information you provide when you answer one of the questionnaires or polls on Our Site or in our marketing emails.

3.3.6 information about whether you opened our emails, what you clicked on, if the email bounced from your inbox, whether you unsubscribed, and whether you made a spam complaint; and

3.3.7 any other information you voluntarily provide to us via Our Site or other media (including email, telephone, post or social media) following your subscription to our marketing emails.

3.4 If you have agreed to receive “push notifications”, we will collect and process:

3.4.1 your IP address; and

3.4.2  information regarding which notifications you receive, open, click on, and to which you unsubscribe.

3.5 If you have agreed to receive our WhatsApp newsletter, we will collect and process:

3.5.1 your mobile number;

3.5.2 the time you subscribed; and

3.5.3 information regarding the messages and offers you receive, open, click on, and to which you unsubscribe:

3.6 If you contact us (whether by email, telephone, letter or social media), we will collect any information contained in the correspondence between us.

4. The basis on which we process your personal information

4.1 As a visitor to Our Site or a subscriber to our marketing communications, we will only ever process your personal data on the following grounds:

4.1.1 our legitimate interests (see further detail in paragraphs 4.6 and 4.7 below on what is meant by “legitimate interests”);

4.1.2 your consent (where you have provided it); and/or

4.1.3 compliance with our legal obligations.

4.2 When you use Our Site (and regardless of whether you subscribe to our marketing communications), we may:

4.2.1 use your information to provide you with access to Our Site in a manner convenient and optimal and with personalised content relevant to you, including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);

4.2.2 collect information about you (such as your IP address) from your use of Our Site and share this with third parties and advertising platforms (such as Google, Bing, Facebook & Twitter), so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of our legitimate interests to market our products to you and others who have similar preferences to you. More information can be found in the Cookie Policy, including how to disable these cookies so that we cannot collect information about you;

4.3 Once you have subscribed to receive marketing emails from us, in addition to the processing activities set out in paragraph 4.2, we may:

4.3.1 use your information to send you, via our third party email provider (Campaign Monitor), marketing emails about offers and products that we and our commercial partners believe may interest you (provided that we have your consent to do so) and share your information with our marketing services provider (on the basis of your consent). Please note that the emails we send are frequent (typically twice daily). Further details regarding the type of offers we send are included in paragraph 12 below

4.3.2 collect and analyse information in order to further personalise the content that we provide to you on Our Site and via our marketing emails (on the basis of your consent) from your engagement with the following:

4.3.3 our marketing emails (including which emails you have opened, items you have clicked on); and

4.3.4 share your personal information with selected third parties and advertising platforms (such as Google, Bing, and Facebook) so that we can stop you from seeing ads if you are already a member of our mailing list, and so that relevant adverts may be selected and served to you, and others who are similar to you, via those platforms (on the basis of your consent); and

4.3.5 your use of Our Site (as outlined in paragraph 3.2 above);

4.3.6 where you have unsubscribed from our marketing emails, keep a record of your email address to ensure that it is not used to sign up to our marketing emails again.

4.4 If you have agreed to receive “push notifications”, we will share your IP address with a third party push notification provider (Pushcrew) so that they can provide you with personalised offers and content while you are on Our Site (on the basis of your consent).

4.5 If you have requested to join our WhatsApp newsletter (i.e. by sending a WhatsApp message to the number provided), we will collect your mobile number via our WhatsApp newsletter provider (Messenger People) so that they can, on our behalf, provide you with personalised offers and content (on the basis of your consent).

4.6 Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interests we have in:

4.6.1 performing as a profitable and sustainable company that uses marketing activity as its primary revenue source;

4.6.2 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;

4.6.3 detecting and preventing fraud and operating a safe and lawful business; and/or

4.6.4 improving security and optimisation of our network, sites and services.

4.7 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don ‘t automatically override yours and we won ‘t use your information if we believe that your interests should override ours unless we have other grounds to do so (such as your consent or have a legal obligation to do so). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 8 below.

Third parties with whom we might share your information

In connection with the purposes and on the lawful grounds described above, we may share your personal information with third parties. These include:

5. Third parties with whom we might share your information

    1. Google Analytics – Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ;
    2. Google Adwords – Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ;
    3. Hotjar – Level 2, St Julian ‘s Business Centre, 3, Elia Zammit Street, St Julian ‘s STJ 1000, Malta;
    4. New Relic – 188 Spear St., Suite 1200, San Francisco, CA USA 94105;
    5. Codebase HQ – Unit 9 Winchester Place, North Street, Poole, Dorset, BH15 1NX;
    6. Facebook – 10 Brock St, London NW1 3FG;
    7. Bing – Thames Valley Park, Reading, RG6 1WG;
    8. Campaign Monitor – Campaign Monitor, Level 38, 201 Elizabeth Street, Sydney, NSW 2000, Australia;
    9. Pushcrew – 14th Floor, KLJ Tower North, Netaji Subhash Place, Pitam Pura, Delhi, 110034, India;
    10. Messenger People – Schwanthalerstr. 32, 80336, München; and
    11. Rackspace – 5 Millington Road, Hyde Park Hayes, Middlesex, UB3 4AZ;
    12. Twitter – 20 Air St, Soho, London W1B 5AG

5.1 any member of our group, which means our subsidiaries, our ultimate group holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

5.2 any prospective seller or buyer of our business or assets, only in the event that we decide to sell or buy any business or assets; and/or

5.3 any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

6. How we look after your information and for how long we keep it

6.1 We will not keep your information for longer than is necessary. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.

6.2 Subject to paragraph 6.4 below, if you are a subscriber to our marketing emails, WhatsApp messages or push notifications, we will retain your information for as long as you are a subscribed user (i.e. you are subscribed to receive our emails, WhatsApp messages and/or push notifications).

6.3 If you are not subscribed to our marketing emails, WhatsApp messages or push notifications, we will retain your information for 180 days following the last interaction with Our Site.

6.4 We may, however, retain for longer periods:

  • your email address, telephone number and IP address to ensure that you cannot be re-subscribed to our marketing emails, WhatsApp messages and/or push notifications;
  • any information where it may reasonably be required for legal proceedings; or
  • for security purposes.

7 International transfers of your information

7.1 Our business is located in the UK and the European Economic Area (EEA).

7.2 Your personal information will not be processed outside of the EEA, except where we use a third party service provider with servers located outside the EEA. We take all steps necessary to ensure that any of your information which is passed to third parties is adequately protected and processed in accordance with this Privacy Policy, including but not limited to using all appropriate cross-border transfer solutions such as the European Commission’s Standard Contractual Clauses or the EU-US Privacy Shield Framework.

8 Your rights in respect of your personal information

8.1 You have the following rights under the GDPR:

8.1.1 right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one detailed summary of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs); and

8.1.2 right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and

8.2 in certain circumstances, you will also have the following rights:

8.2.1 right to withdraw consent: we rely on your consent for certain processing operations, including processing the personal data you provide to us, or that we collect, for marketing purposes. You have the right to withdraw your consent. If you do that, we’ll update our records immediately to reflect your wishes. If you only wish to unsubscribe from certain communications, please see below).

8.2.2 right to object: the right to object to our use of your personal information including where we use it for our legitimate interests.

8.2.3 right to erasure/”right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to retain the information, or certain information, for compliance with any legal obligation);

8.2.4 right to restriction of use of your information: the right to stop us from using your personal information or to limit the way in which we can use it; and

8.2.5 right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible.

8.3 Please note that if you withdraw your consent to the use of your personal information for purposes set out in this Privacy Policy, we may not be able to provide you with access to all or certain parts of our services.

8.4 If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office. Please see further information on their website:

9 Unsubscribe

9.1 E-mail mailing list

You may unsubscribe from our e-mail mailing list at any time. To unsubscribe you may do any of the following:

9.1.1 send us an email at hello@freebiefreedom and ask to unsubscribe

9.1.2 click the ‘unsubscribe’ link which is situated at the bottom of every e-mail we send


9.2 You may unsubscribe from our WhatsApp mailing list at any time. To unsubscribe you may reply to any of our messages with ‘Stop’.

9.3 Browser ‘push’ notifications

You may unsubscribe from our browser notification mailing list at any time. 

10 Automatic decision making

We may analyse your personal information to create a profile of your interests and preferences so that we can personalise Our Site and communications so that they are more relevant to you.

11 Security

11.1 We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

11.1.1 where appropriate, data is encrypted when transiting on our system or stored on our databases;

11.1.2 we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and

11.1.3 we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

11.2 While we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.

12 Categories of marketing

As mentioned in section 1, some of our communications are used for 3rd party advertising, the categories of marketing you can expect to receive are: Baby, Beauty, Entertainment, Fashion, Finance, Food & Drink, Gambling, Health & Fitness, Home & Garden, Kids, Learning, Pets, Sports & Outdoors, Technology, Travel

13 Changes to this Privacy Policy

We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Policy).

14 Minimum Age

You must be aged 18 or over to register for marketing (by any channel) from Magic Freebies. We do not knowingly, deliberately or aim to, collect personal data from any body under the age of 18, either for registration or for marketing purposes.

15 Cookies

We use cookies to ensure that you get the most out of Our Site and our marketing emails. Please find further details in the Cookie Policy.

Cookie Policy

Cookies help us to provide you a better website, enabling us to see which pages you find useful and which ones you don’t.

When you visit a domain, the assets that are loaded on that domain may drop a third-party cookie. These sometimes allow the third party to track you from one site to the other.

You can choose to accept or decline cookies if you prefer by adjusting the setting within your web browser.

If you want to stop cookies being stored on your device in future, please refer to your browser manufacturer’s instructions by clicking ‘Help’ in your browser menu.

Cookie Analytics

We work with advertisers & marketing partners to fund the site and keep it free for use by the public.

These 3rd parties use cookie technologies to collect data for analytics purposes. By continuing to use this Our Site, including clicking any external links, you consent to the use of advertising and analytics technologies (including cookies) on Our Site and with any advertising partners of Our Site. You also consent to the use of cookies by our own advertising network which runs on the domain


We have placed some code on our website from Google Analytics, Google Adwords, Facebook & Bing which uses cookies to allow us to ‘re-target’ users with online adverts when they visit other websites. You can opt out of this activity via:

  1. Google Analytics/Adwords – DoubleClick opt-out page or the Network Advertising Initiative opt-out page
  2. Facebook – Login to your Facebook account and visit Settings → Ads where you can customise your settings
  3. Bing – Visit the opt out page
  4. Twitter – Visit the opt out page

Web analytics

We use Google Analytics to assess the number of visitors, sessions, page views, user journeys etc. We use this information to optimise the website and future marketing campaigns, however, it doesn’t include any personally identifiable information.

We use Hotjar to log and understand user interactions on site to help improve our service.

Email tracking technology and clear gifs

We send e-mails using Campaign Monitor. Their platform records e-mail analytics on an individual user basis including (but not limited to) who was sent particular e-mails, opens, clicks, bounces & unsubscribes. The data is gathered using industry standard technologies including clear gifs.