Privacy Policy


Freepoint Eco-Systems LLC and the other Freepoint Commodities LLC group companies (collectively “Freepoint Group”) are responsible for your personal information and we take our data protection and privacy responsibilities seriously.

This privacy notice explains how we collect, use and share personal information in the course of our business activities.


We collect personal information about you if you:

  • Are a current, ex, or prospective employee, intern or contractor;
  • Represent a trading partner, third party vendor or service provider of the Freepoint Group; or
  • Use this website, (see Cookie section below).

Personal information we collect, use and store if you are a current, ex, or prospective employee, intern or contractor:

  • Staff related data: identification information (name, address, date of birth, etc.);
  • Employment related data: title, location, salary, employment history, leave information, health information and assessments of your working capacity, etc.

Personal information we collect, use and store if you are a representative of a trading partner, third party vendor or service provider:

  • Onboarding information: proof of identity to satisfy Know Your Customer or other legal, regulatory, or due diligence requirements;
  • Contact details: to enable us to satisfy communication or contractual requirements.

We will only collect and process personal data where we have a lawful basis for doing so, as defined by the EU General Data Protection Regulation and other applicable laws.

Specifically we collect or process personal data where we have one or more of the following lawful basis:

  • Legitimate interests (including our commercial interests in operating our business);
  • Contractual obligations (including for the performance of contracts of employment or engagement with the Freepoint Group); or
  • Legal obligations (including our obligations in the field of employment law). 

For the purposes referred to in this Privacy Policy and relying on the lawful bases for processing as set out above, we may share your personal data with certain third parties including: other employees, agents and contractors (on a strictly ‘need to know’ basis); service providers and advisers engaged by the Freepoint Group, including auditors and accountants, health and safety professionals and legal advisers; and competent authorities, including courts, regulators and tax authorities when we are legally required to do so.


We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU, including but not limited to the United States of America, that are subject to different standards of data protection.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws and are carefully managed to protect your privacy rights and interests. To this end:

  • we will ensure transfers within the Freepoint Group will be covered by an agreement entered into by members of the Freepoint Group (an intra‑group agreement) which contractually obligates each member to ensure that personal information receives an adequate and consistent level of protection;
  • where we transfer your personal information outside the Freepoint Group, we obtain contractual commitments from such parties to protect your personal information.



We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access of such information. Such measures, policies and procedures will be appropriate to the nature of the information concerned. 

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.


Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.

  • To access personal information
  • To rectify / erase personal information
  • To restrict the processing of your personal information
  • To transfer your personal information
  • To object to the processing of personal information
  • To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
  • To lodge a complaint with your local supervisory authority 

If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.


A cookie is a small text file containing small amounts of information which is downloaded to and stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website. Cookies are pieces of information transferred to your hard drive for record-keeping purposes.  The use of cookies is an industry standard and is used by most major websites to provide the visitor with tailored information.

Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your country, language and other settings. Cookies allow us to understand who has seen which webpages, to determine how frequently particular pages are visited and to determine the most popular areas of our website. They can also help us to operate our website more efficiently and make your next visit easier.

You can choose not to accept the cookie by adjusting your browser settings, but, if you choose to do so, not all parts of the website might function properly.


If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to contact us  We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timeframes provided by data protection laws.