FREEMEDIA PRIVACY POLICY

Trade to Travel Inc. | Freemedia

Effective Date: July 24, 2026
Version: 2.1

Privacy Policy Welcome

Privacy Policy: Welcome to Freemedia.

Freemedia is a social media platform that enables users to create, edit, upload, discover, and share short-form videos and to interact with other users through features such as likes, comments, follows, reposts, private messaging, content recommendations, and translation.

This Privacy Policy explains how Trade to Travel Inc. collects, uses, stores, discloses, transfers, and protects personal information when you access or use the Freemedia mobile application, website, and related services collectively referred to as the “Services.”

Trade to Travel Inc. is responsible for the processing of personal information described in this Privacy Policy, except where another party is independently responsible under applicable law.

By creating an account or using the Services, you acknowledge that you have read this Privacy Policy. Where consent is required by applicable law, Freemedia will request it separately through an appropriate notice or affirmative action.

1. Who We Are

Freemedia is operated by:

Trade to Travel Inc.

Trinity Chambers P.O. Box 4301 Road Town, Tortola British Virgin Islands

For the purposes of applicable data protection laws, Trade to Travel Inc. is the controller or business responsible for the personal information processed through the Services, except where otherwise stated.

Privacy Contact

Privacy-related questions, requests, and complaints may be directed to:

Privacy Contact: Leah Email: leah@tradetotravel.com

General support, account-deletion assistance, safety reports, and platform-related enquiries may be directed to:

Support and Reporting Contact: Rachel Email: rachel@tradetotravel.com

2. Scope of this Policy

This Privacy Policy applies to personal information processed through:

  • The Freemedia mobile application.
  • The Freemedia website and associated web pages that link to this Privacy Policy.
  • User accounts and profiles.
  • User-generated content.
  • Messaging and media-sharing features.
  • Translation, recommendation, and personalization features.
  • Reporting, moderation, blocking, and appeal functions.
  • Account recovery and account-deletion processes.
  • Customer support and other communications with Freemedia.
  • Administrative, security, and platform-management activities.

This Privacy Policy applies regardless of the country from which you access the Services.

It does not govern third-party websites, applications, or services that operate independently from Freemedia and publish their own privacy policies.

3. Minimum Age

Freemedia is intended for individuals who are at least 13 years old.

We do not knowingly permit children under 13 to create accounts or knowingly collect personal information from them. Where the law of a user’s jurisdiction requires parental or guardian authorization for a person aged 13 or older to use the Services or for certain processing activities, Freemedia may request such authorization or restrict access as required by law.

If we reasonably believe that an account belongs to a child under 13, we may suspend or close the account and take reasonable steps to delete associated personal information, subject to any lawful retention requirements.

A parent or legal guardian who believes that a child under 13 has provided personal information to Freemedia may contact us using the details in Section 23.

4. Information We Collect

The information we collect depends on how you use the platform.

A. Information You Provide When creating or managing an account, you may provide:

  • Full name
  • Username
  • Email address
  • Authentication credentials, which are stored or processed using appropriate protective measures, such as secure hashing, encryption, or authentication tokens, depending on the authentication method used.
  • Profile photograph
  • Biography
  • Profile preferences

Registration requires a username, name, email address, and password. One-time password (OTP) verification is used during registration, account recovery (including forgotten-password requests), and when a user changes the registered email address.

B. Content You Create When using Freemedia, you may create or upload:

  • Videos
  • Images used as thumbnails or profile photos
  • Captions
  • Titles
  • Hashtags
  • Comments
  • Reposts
  • Direct messages
  • Audio messages
  • Shared media within conversations

Content that you choose to publish may be visible to other users depending on your privacy settings and the nature of the feature being used. Uploaded images and videos may contain embedded file metadata, such as timestamps, device information, file characteristics, or location metadata (including EXIF data) where present in the selected file.

C. Information Generated Through Your Activity To operate the platform, we record information relating to your use of the Services, including:

  • Videos viewed
  • Likes
  • Comments
  • Follows
  • Followers
  • Reposts
  • Favorites
  • Searches
  • Notifications
  • Reports submitted
  • Blocked users
  • Language preferences
  • Account settings

This information helps provide core platform functionality, personalize content within the application, and maintain the integrity and security of the service.

D. Device, Network, and Technical Information When you access or use the Services, Freemedia and its service providers may automatically process limited technical information needed to operate, secure, diagnose, and improve the Services.

Depending on the device, operating system, configuration, and features used, this information may include:

  • Device type and model.
  • Operating system and version.
  • Application version.
  • Language and time-zone settings.
  • Internet Protocol address.
  • Network connection information.
  • Device-generated or application-generated identifiers.
  • Login dates and times.
  • Session and authentication information.
  • Diagnostic logs.
  • Crash reports and error information.
  • Security events and suspected fraudulent activity.
  • Information about feature performance and service availability.

This information is used to provide compatibility, maintain sessions, diagnose errors, protect accounts, prevent fraud and abuse, and maintain the reliability and security of the Services.

Freemedia does not use this information to serve third-party targeted advertising. Certain operational service providers may process technical identifiers for installation attribution, deep-linking, security, diagnostics, or service operation as described in this Policy.

E. Location Information

Where a feature requires location functionality and you permit location access, Freemedia may process device location information, including latitude and longitude. Location information may be processed by contracted mapping, messaging, infrastructure, or service providers as necessary to provide the selected functionality.

F. Device Permissions and User-Selected Media Freemedia may request access to specific device features only when needed to provide a feature selected by you.

These permissions may include:

  • Camera: To allow you to record videos or capture images for upload or sharing.
  • Microphone: To record audio when you create videos, record audio messages, or use another audio-enabled feature.
  • Photos, Media, or Device Storage: To allow you to select, upload, save, or share media.
  • Push Notifications: To deliver notifications relating to account activity, messages, content interactions, security alerts, and other platform activity.

Freemedia does not activate the camera or microphone continuously. Camera and microphone access occurs only when you use a feature that requires it and after the relevant device permission has been granted.

Freemedia does not collect, create, or store biometric identifiers or biometric templates for the purpose of identifying users. Camera and microphone access is used solely to enable user-selected media creation, messaging, and other communication features available through the Services.

Freemedia does not scan or upload your entire photo library. It processes only the media you select or create through the Services, subject to the access model provided by your device and operating system.

You may grant or deny permissions when prompted and may later revoke them through your device settings. Certain features may not function if the relevant permission is denied or revoked.

Granting a device permission does not authorize Freemedia to use the resulting information for purposes unrelated to the feature for which the permission was requested.

G. Information Received From Other People Freemedia may receive information about you from other users or third parties, including when:

  • Another user reports your account, content, comment, or message.
  • Another user mentions, shares, reposts, or sends content involving you.
  • A copyright or other rights complaint identifies you or your content.
  • A user submits evidence as part of a moderation report or appeal.
  • A competent authority submits a lawful request.
  • A service provider supplies security, fraud-prevention, authentication, or technical information.

We use this information only for the purposes described in this Privacy Policy, including platform safety, rights protection, legal compliance, account security, and dispute resolution.

5. How We Use Your Information

Freemedia uses your information only for legitimate purposes necessary to provide, maintain, improve, and protect our Services.

We use your information to:

Account Management

  • Create and maintain your account.
  • Verify your email during registration, account recovery, and supported account changes.
  • Authenticate access using the account credentials and verification methods supported by the Services.
  • Recover access to your account when requested.
  • Manage your profile and preferences.

Providing Our Services

We use your information to deliver the features and functionality of Freemedia, including:

  • Creating, editing, uploading, and publishing videos.
  • Displaying your public profile.
  • Managing followers and following relationships.
  • Enabling likes, comments, reposts, and other user interactions.
  • Delivering private messages and shared media.
  • Translating supported content when you request translation.
  • Synchronizing your account across supported devices.
  • Delivering push notifications relating to your account and platform activity.

Personalizing Your Experience

Freemedia provides a personalized experience to improve content discovery.

This may include:

  • Recommending videos based on your activity.
  • Displaying content relevant to your interests.
  • Showing creators you may wish to follow.
  • Remembering your preferred language.
  • Presenting translated content where supported.
  • Remembering your application settings and preferences.

These recommendations are intended solely to improve your experience and do not produce legal or similarly significant effects.

Platform Security

Your information is used to help protect both you and the Freemedia community by:

  • Detecting spam and fake accounts.
  • Preventing unauthorized access.
  • Investigating suspected abuse or fraudulent activity.
  • Enforcing our Terms of Service and Community Guidelines.
  • Maintaining the security, availability, and reliability of the Services.
  • Detecting coordinated manipulation, artificial engagement, unauthorized automation, and abuse of platform features.
  • Reviewing reports, moderation decisions, appeals, copyright complaints, and counter-notifications.
  • Identifying content or activity that may threaten child safety or create a risk of physical harm.
  • Enforcing account restrictions, suspensions, and terminations where appropriate.
  • Preserving relevant information where reasonably necessary to investigate security incidents, fraud, abuse, or unlawful activity.

Recommendations, Translation, and Automated Systems

Freemedia may use automated technologies, including machine-learning and artificial-intelligence-supported systems, to:

  • Recommend and rank videos or creators.
  • Personalize content feeds.
  • Translate posts, comments, messages, or other supported content.

User reports and moderation decisions are currently reviewed by authorized human personnel rather than by an AI-first moderation process.

Improve the relevance, security, reliability, and performance of the Services.

These systems may process information such as your selected interests, viewing activity, likes, comments, follows, searches, language preferences, reports, account settings, device information, and other usage signals.

Automated recommendations and translations may be inaccurate or incomplete. Freemedia does not use automated systems to make decisions that produce legal or similarly significant effects about users unless appropriate safeguards are provided as required by applicable law.

Where user content or personal information is processed by a third-party artificial-intelligence or translation provider, the provider may process that information only to provide the contracted service and subject to applicable contractual and security safeguards.

Customer Support

If you contact Freemedia, we may use your information to:

  • Respond to your enquiries.
  • Investigate technical issues.
  • Resolve account-related concerns.
  • Provide assistance with platform features.
  • Improve the quality of customer support.

Legal Compliance

We may process your information where necessary to:

  • Comply with applicable laws and regulations.
  • Respond to lawful requests from competent authorities.
  • Protect our legal rights and those of our users.
  • Investigate or prevent unlawful activities.
  • Enforce our agreements and platform policies.

7. User Generated Content

Freemedia is a platform built around user-generated content.

By uploading or publishing content through Freemedia, you grant us a limited, non-exclusive, worldwide licence to host, store, process, reproduce, display, transmit, and distribute your content solely for the purpose of operating, maintaining, securing, and improving the Services.

You retain ownership of the videos, photographs, comments, messages, audio, profile information, and other content you create or upload.

When you upload or publish User Content through the Services, you grant Freemedia the licence described in the Terms of Service. This licence permits Freemedia to host, store, process, reproduce, display, distribute, transmit, format, technically adapt, and make the content available to other users in accordance with the visibility options available through the Services.

The licence is used only to operate, maintain, secure, improve, and promote the Services.

The licence ends when the content is permanently removed from active systems, except where:

  • Retention is required or permitted by law.
  • The content has already been delivered to or independently stored by another user.
  • Copies remain temporarily in encrypted backup and disaster-recovery systems.
  • Limited retention is reasonably necessary for fraud prevention, platform safety, dispute resolution, or the establishment, exercise, or defence of legal claims.

Public content that you choose to publish may be viewed, shared, or redistributed by other users. Freemedia cannot control how publicly shared content is used by third parties once it has been made publicly available.

8. Messaging and Translation Services

Freemedia provides private messaging features through which users may send text, images, videos, audio messages, and other supported media.

To provide these features, messages and associated information may be:

  • Stored.
  • Processed.
  • Transmitted.
  • Delivered to recipients.
  • Translated when requested by the user.
  • Reviewed when reasonably necessary to investigate a report, enforce our policies, protect users, prevent fraud, maintain security, or comply with applicable law.

Freemedia does not routinely review the content of all private messages. Messages are encrypted in transit using TLS and encrypted at rest, but messaging is not end-to-end encrypted. Authorized Freemedia personnel and authorized administrators of the messaging service provider may technically access message content where permitted and necessary for service administration, troubleshooting, safety investigations, enforcement, security, or legal compliance.

Automated translations are provided for convenience and may be inaccurate, incomplete, or contextually incorrect. They should not be relied upon as official, professional, certified, or legally binding translations.

Users may delete direct messages using the controls available within the Services. When a supported message-deletion action is completed, the message is removed from the conversation for both the sender and recipient. Limited copies may remain temporarily in encrypted backups or where retention is required by law.

9. How We Disclose Information

Freemedia does not sell personal information.

Freemedia does not disclose personal information to third parties for cross-context behavioural advertising or permit third-party service providers to use Freemedia data for their own advertising or marketing purposes.

We may disclose information in the following circumstances:

Service Providers

We may disclose information to vendors that perform services on our behalf, including:

  • Cloud infrastructure and hosting.
  • Database and secure storage.
  • Video processing and transcoding.
  • Content delivery.
  • Private messaging infrastructure.
  • Translation and artificial-intelligence-supported processing.
  • Email, OTP, and notification delivery.
  • Security, fraud prevention, logging, and access management.
  • Customer support.
  • Backup and disaster recovery.

Service providers are authorized to process information only as necessary to perform contracted services, subject to appropriate confidentiality, data-protection, and security obligations.

Material service providers used in connection with the Services may include:

  • Amazon Web Services (AWS) and AWS S3/CloudFront for hosting, storage, content delivery, backups, and uploaded media.
  • Stream Chat for messaging, which may process user identifiers, profile information, messages, media, language, location information where used, and push-device tokens.
  • Firebase services for account/application identifiers, profile information, push tokens, and related application functionality.
  • Postmark for transactional email delivery; the exact email data processed depends on the message being sent.
  • Apple Push Notification service and Firebase Cloud Messaging for push notifications.
  • AppsFlyer for application installation attribution and deep-link functionality, which may involve device or advertising identifiers and attribution/deep-link data.
  • Branch, where currently enabled, for install and deep-link metadata.
  • Google, Apple, and Facebook authentication services where a user chooses the applicable sign-in method.
  • Google Maps or geolocation services for location functionality selected by the user.
  • Media-editing or video-editor SDK providers where used to enable editing functionality.

The specific provider set may change as the Services evolve. Freemedia will update this Policy where a material change affects how personal information is processed.

Other Users and the Public

Information is disclosed to other users when you:

  • Publish public content.
  • Maintain a public profile.
  • Comment, like, follow, repost, or otherwise interact publicly.
  • Send a message or media to another user.
  • Use a feature that makes information available to a selected audience.

The visibility of information depends on the feature, the available privacy settings, and the choices you make.

Legal, Safety, and Rights Protection

We may preserve or disclose information where we reasonably believe it is necessary to:

  • Comply with applicable law, legal process, or a valid request from a competent authority.
  • Protect the rights, safety, and security of Freemedia, its users, or another person.
  • Investigate fraud, child exploitation, credible threats, unlawful activity, or security incidents.
  • Enforce our Terms and policies.
  • Respond to copyright, intellectual property, privacy, or other rights complaints.
  • Establish, exercise, or defend legal claims.

Where permitted, we assess legal requests for validity, scope, and authority before disclosing information.

Corporate Transactions

If Trade to Travel Inc. is involved in a merger, acquisition, financing, restructuring, sale of assets, insolvency, or similar transaction, information may be disclosed to advisers, counterparties, or successors subject to appropriate confidentiality and legal safeguards.

With Your Direction or Consent

We may disclose information where you direct us to do so or provide consent.

Service-Provider Information Freemedia may publish and update a list of material service-provider categories or providers through its website or within the Services.

The specific providers used may change as Freemedia’s infrastructure and features evolve. Any provider that processes personal information on Freemedia’s behalf must be assessed for appropriate privacy, security, confidentiality, and contractual protections.

10. International Data Transfers

Freemedia operates internationally, and personal information may be processed in countries other than the country in which you live.

Where applicable law requires safeguards for an international transfer, Trade to Travel Inc. will use an appropriate lawful transfer mechanism and contractual or technical safeguards appropriate to the relevant transfer. Because service providers may operate infrastructure in multiple jurisdictions, the exact processing location may vary by provider and service configuration.

Service providers may process information only for authorized purposes and subject to applicable contractual and security requirements.

You may contact us for further information regarding the safeguards applicable to a particular international transfer, subject to legal and confidentiality limitations.

11. Cookies and Similar Technologies

The Freemedia mobile application does not use traditional browser cookies. However, the application may use:

  • Authentication tokens.
  • Session identifiers.
  • Application-instance identifiers.
  • Device or push-notification tokens.
  • Security identifiers.
  • Local storage or similar application technologies.

These technologies may be used to:

  • Keep users securely signed in.
  • Maintain active sessions.
  • Remember settings and preferences.
  • Deliver requested notifications.
  • Prevent unauthorized access, fraud, spam, and abuse.
  • Diagnose errors and maintain service reliability.

Freemedia does not use these technologies for third-party advertising or cross-application tracking.

The Freemedia website may use strictly necessary cookies, hosting logs, or similar technologies required for security, account-deletion requests, session management, or basic website operation. If Freemedia later introduces non-essential analytics or advertising technologies, it will provide appropriate notice and consent controls where required.

12. Analytics, Diagnostics, and Service Improvement

Freemedia does not use personal information to serve third-party targeted advertising. Certain service providers may process device, installation, attribution, deep-link, diagnostic, or operational information to operate and measure the Services.

Freemedia may process operational and diagnostic information internally or through contracted service providers where necessary to:

  • Monitor system performance.
  • Diagnose crashes and technical errors.
  • Maintain compatibility.
  • Measure feature reliability.
  • Detect fraud, spam, abuse, and security incidents.
  • Understand aggregated platform usage.
  • Improve the availability, safety, and performance of the Services.

Operational analytics may involve device, application, session, interaction, and diagnostic information described in this Privacy Policy.

Freemedia does not permit analytics or diagnostic providers to use this information for their own advertising or unrelated marketing purposes.

13. Data Security

Freemedia is committed to protecting your personal information through appropriate technical and organizational security measures.

These measures include, where appropriate:

  • Encryption of data during transmission using secure communication protocols.
  • Encryption of sensitive information at rest where applicable.
  • Access controls restricting information to authorized personnel.
  • Identity and access management controls.
  • Secure cloud infrastructure.
  • Network security protections.
  • Regular security monitoring.
  • Disaster recovery procedures.
  • Encrypted backups.
  • Security auditing and logging.

While we take reasonable measures to protect your information, no method of electronic storage or transmission over the Internet can be guaranteed to be completely secure. Users should also take reasonable steps to protect their account credentials and devices.

14. Security Incidents

Freemedia maintains procedures designed to identify, assess, contain, and respond to suspected security incidents involving personal information.

Where required by applicable law, Freemedia will notify affected users, regulators, or other competent authorities of a qualifying personal data breach within the applicable timeframe.

No security measure can eliminate all risk. Users should protect their account credentials, keep their devices secure, and promptly report suspected unauthorized access.

15. Data Retention

Freemedia retains personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing the Services, maintaining security, complying with law, resolving disputes, enforcing agreements, and protecting users.

Retention depends on the category of information and the reason it is processed.

Account and Profile Information

Account and profile information is generally retained while the account remains active. When a deletion request is completed, user access is terminated immediately and the account is no longer available to the user. Under the current technical implementation, certain underlying records may remain in active systems with the user status changed to reflect deletion or closure. Such records may be retained only as necessary for service integrity, legal compliance, fraud prevention, security, dispute resolution, or legal claims, and are not restorable by the user.

User-Generated Content

Videos, images, comments, captions, profile content, and other User Content are generally retained until deleted by the user, removed by Freemedia, or deleted as part of account closure.

Content that has been copied, shared, reposted, quoted, delivered to another user, or independently stored by another person may remain outside Freemedia’s control.

Messages

Messages are generally retained for as long as needed to provide the messaging service. Where a user deletes a direct message using a supported deletion control, the message is removed from the conversation for both participants, subject to temporary backup retention or lawful retention requirements.

Reported messages or limited message records may be retained longer where reasonably necessary for safety investigations, fraud prevention, policy enforcement, legal compliance, or legal claims.

Reports, Moderation, and Appeals

Reports and related moderation information may be retained where necessary to review reports, document enforcement actions, protect users, resolve disputes or available appeals, prevent abuse, and establish or defend legal claims. The retention period depends on the nature and purpose of the record. No separate moderation-log retention period is currently specified.

Copyright and Rights Complaints

Copyright notices, counter-notifications, rights complaints, and associated records may be retained for as long as reasonably necessary to process the complaint, address repeat infringement, comply with law, and maintain evidence of the procedure followed.

Security and Technical Records

Authentication records, security events, fraud-prevention information, logs, and diagnostic records may be retained for a limited period appropriate to security, troubleshooting, incident response, legal compliance, and platform integrity.

Support Communications

Support requests and related communications may be retained for as long as reasonably necessary to resolve the request, maintain service records, train authorized support personnel, resolve disputes, and improve support quality.

Legal Retention

Information may be retained longer where required or permitted by law, court order, regulatory requirement, litigation hold, child-safety obligation, fraud investigation, or the establishment, exercise, or defence of legal claims.

Deletion or Anonymization

When personal information is no longer required, Freemedia will delete it, anonymize it, or otherwise place it beyond practical use, subject to technical limitations and lawful retention requirements.

16. Backup and Disaster Recovery

To help ensure service continuity and protect against accidental data loss, Freemedia maintains daily database backups and weekly server snapshots. Backup snapshots are encrypted.

Backup copies are retained for up to four (4) weeks for disaster recovery and business continuity purposes.

These backups are:

  • Encrypted.
  • Access restricted.
  • Not used for day-to-day operations.
  • Automatically overwritten or removed through the normal four-week backup rotation, unless a particular backup or record must be preserved for security investigation, disaster recovery, litigation hold, or another lawful requirement.

unless a particular backup or record must be preserved for security investigation, disaster recovery, litigation hold, or another lawful requirement.

Where a user requests deletion of their account, the user-facing account is closed immediately in accordance with our deletion procedures. Limited copies of information may remain within encrypted backup archives until those backups expire through the normal four-week backup rotation.

17. Your Privacy Rights

Depending on where you live and subject to applicable law, you may have the right to:

  • Request confirmation of whether Freemedia processes your personal information.
  • Access personal information held about you.
  • Correct inaccurate or incomplete information.
  • Request deletion of personal information.
  • Request restriction of certain processing.
  • Object to certain processing.
  • Receive certain information in a portable format.
  • Withdraw consent where processing is based on consent.
  • Opt out of the sale or sharing of personal information where such rights apply.
  • Request information about categories of information collected, used, or disclosed.
  • Appeal the denial of a privacy-rights request where applicable law provides an appeal right.
  • Lodge a complaint with a competent data-protection or privacy authority.
  • Receive equal service and not be unlawfully discriminated against for exercising a privacy right.

To protect user information, Freemedia may take reasonable steps to verify your identity and authority before completing a request.

Authorized agents may submit requests where permitted by applicable law. Freemedia may require proof that the agent is authorized to act on your behalf and may request direct verification from you.

Freemedia will respond within the period required by applicable law. Certain requests may be limited or refused where permitted by law, including where necessary to:

  • Protect another person’s rights or safety.
  • Prevent fraud or abuse.
  • Preserve freedom of expression.
  • Comply with legal obligations.
  • Maintain security records.
  • Establish, exercise, or defend legal claims.
  • Retain records of moderation or unlawful activity.

You may submit a privacy request by contacting leah@tradetotravel.com.

17.1 App Store Privacy Disclosures and Parental Consent For purposes of compliance with Apple App Store and Google Play Store requirements, Freemedia confirms that:

  • Personal information collected is linked to the user’s account only for the purpose of providing core functionality (e.g., login, messaging, content sharing).
  • Freemedia does not use personal information to serve third-party targeted advertising or sell personal information for advertising purposes. Certain operational providers may process device, installation, attribution, or deep-link information as described in this Policy.
  • Freemedia does not use personal information to serve third-party targeted advertising or sell personal information for advertising purposes. Certain operational providers may process device, installation, attribution, or deep-link information as described in this Policy.
  • Where applicable law requires parental consent for users aged 13–16, Freemedia will request such consent through appropriate verification measures before allowing access to certain features.

These disclosures align with Apple’s App Privacy labels and Google Play’s Data Safety requirements, ensuring transparency and user control.

18. California Privacy Rights

If you are a resident of California, you have certain rights under the California Consumer Privacy Act (CCPA) and related laws. These include the right to:

  • Request access to the categories and specific pieces of personal information we have collected about you.
  • Request deletion of personal information, subject to lawful exceptions.
  • Request disclosure of the categories of personal information collected, the sources of that information, the business or commercial purposes for collection, and the categories of third parties with whom we share information.
  • Not be discriminated against for exercising your privacy rights.

Freemedia does not sell personal information. We also do not share personal information for cross-context behavioral advertising.

To exercise your California privacy rights, please contact us at:

Email: leah@tradetotravel.com

Postal Address: Trade to Travel Inc., Trinity Chambers, P.O. Box 4301, Road Town, Tortola, British Virgin Islands

We may need to verify your identity before processing your request. Authorized agents may submit requests on behalf of California residents, subject to verification requirements.

18. United States State Privacy Disclosures

Where applicable state privacy law applies, Freemedia may be required to provide additional disclosures regarding categories of personal information.

Depending on how you use the Services, Freemedia may process the following categories:

  • Identifiers, such as name, username, email address, IP address, or account identifiers.
  • Customer-record information, such as contact and account details.
  • Internet or electronic network activity, such as views, interactions, searches, session data, and diagnostic logs.
  • User-generated audio, visual, and electronic content.
  • Inferences used to recommend content or personalize the Services.
  • Account credentials and other information treated as sensitive under applicable law.
  • Communications and support information.

Freemedia uses these categories for the purposes described in this Privacy Policy.

Freemedia does not sell personal information for monetary consideration and does not share personal information for cross-context behavioural advertising.

Freemedia does not knowingly sell or share the personal information of users under 16 for cross-context behavioural advertising.

Users may exercise applicable state rights using the contact details in this Privacy Policy.

Freemedia will not unlawfully discriminate against a user for exercising a privacy right.

19. European Economic Area, United Kingdom, and Switzerland

Where the GDPR, UK GDPR, Swiss data-protection law, or comparable legislation applies:

  • Trade to Travel Inc. acts as the controller for the processing described in this Privacy Policy.
  • The legal bases described in this Policy apply as relevant.
  • Users may exercise applicable access, correction, deletion, restriction, objection, portability, consent-withdrawal, and complaint rights.
  • Users may lodge a complaint with the supervisory authority responsible for their country or region.
  • International transfers will be made using an available lawful mechanism where required.

Freemedia does not use automated decision-making that produces legal or similarly significant effects concerning users without providing the safeguards required by applicable law.

20. Managing Your Information

You can manage much of your personal information directly through your account settings.

Subject to the features available within the application, you may:

  • Update your profile information.
  • Change your username where permitted.
  • Update your email address, subject to OTP verification.
  • Change your password.
  • Update your biography and profile image.
  • Manage notification preferences.
  • Manage blocked users.
  • Delete videos you have uploaded.
  • Control your account privacy settings where supported.
  • Submit a request for access to, or a copy of, eligible personal information where such a right is available under applicable law.
  • Request deletion of individual content.
  • Submit or manage an account-deletion request.
  • Manage language and content-preference settings where available.
  • Manage communication and notification choices.
  • Submit a privacy request through the contact information in this Policy.

Certain information relating to completed platform activity, moderation actions, or legal compliance may continue to be retained as required by law or for the protection of the Services.

21. Children's Privacy

Freemedia is intended for users aged 13 and older.

We do not knowingly collect personal information from children under 13. If we learn that a child under 13 has created an account or provided personal information without valid legal authorization, we will take reasonable steps to suspend or close the account and delete associated personal information, subject to lawful retention requirements.

Users between 13 and the age of legal majority may be entitled to additional protections depending on their country. Freemedia may apply age-appropriate safeguards, limit features, request parental or guardian authorization, or take other steps where required by law.

Parents or legal guardians who believe a child under 13 has provided personal information may contact leah@tradetotravel.com.

Freemedia maintains published standards prohibiting child sexual abuse and exploitation and provides mechanisms through which users can report child-safety concerns.

22. Account and Data Deletion

You may request deletion of your Freemedia account and associated personal information:

When an account-deletion request is completed:

  • The user-facing account will be closed immediately and will no longer be accessible to the user. The public profile will no longer be accessible. Under the current technical implementation, certain underlying account, content, or activity records may remain in Freemedia systems with the account status changed to reflect deletion or closure. Such retained information is not restorable by the user and is handled in accordance with this Policy and applicable retention requirements.
  • Personal information associated with the account will be deleted or anonymized where appropriate.
  • Direct messages deleted using a supported deletion control are removed from the conversation for both sender and recipient, subject to temporary backup retention or lawful retention requirements.
  • conversations.
  • Content copied, reposted, quoted, shared, or independently retained by another person may remain outside Freemedia’s control.
  • Limited records may be retained where required or permitted for legal compliance, fraud prevention, child safety, security, dispute resolution, or legal claims.
  • Residual copies may remain temporarily within encrypted backups until overwritten through the normal four-week backup rotation.

Account deletion is permanent and may not be reversible after completion.

Freemedia may take reasonable steps to verify the identity of the requester before deleting the account. Verification will not be used to impose an unnecessary obstacle to deletion.

23. Public Content

Freemedia is a social media platform designed for sharing content with other users.

Information that you choose to make publicly available, including your username, profile image, biography, public videos, captions, hashtags, comments, reposts, and other publicly shared content, may be viewed by other users of the platform.

Depending on the features available, other users may be able to:

  • View your public profile.
  • Follow your account.
  • Like your content.
  • Comment on your content.
  • Repost publicly available content.
  • Share your content using supported sharing features.

Please carefully consider the information you choose to publish, as publicly available content may be copied, shared, or redistributed by other users outside of Freemedia. While we may remove content from our Services when requested or required, we cannot guarantee the removal of copies that have been shared or retained by third parties.

Search engines, third-party websites, or users outside Freemedia may retain or index publicly available content. Adjusting account visibility or deleting content from Freemedia does not necessarily remove copies already cached, indexed, downloaded, or independently stored by third parties.

Freemedia will take reasonable action concerning content under its control where required by law or its policies.

24. Reporting, Blocking, Moderation, and Platform Safety

Freemedia provides in-app tools that allow users to:

  • Report content, accounts, comments, messages, or other behaviour.
  • Block other users.
  • Appeal certain moderation or enforcement decisions where available.
  • Submit child-safety, copyright, privacy, and other rights concerns.

Information submitted through these tools may include account identifiers, reported content, messages, explanations, supporting material, and relevant contextual information.

Freemedia uses this information to:

  • Review reports.
  • Protect users.
  • Enforce the Terms of Service and Community Guidelines.
  • Investigate fraud, abuse, threats, child-safety concerns, and unlawful activity.
  • Apply account restrictions or other enforcement measures.
  • Review appeals.
  • Maintain evidence and audit records.
  • Comply with applicable law.

Reports are currently reviewed by authorized human personnel. Freemedia may use automated technologies for recommendations, translation, security, reliability, and other supported platform functionality, but reports are not currently reviewed through an AI-first moderation process. Reports involving child safety, credible threats, imminent physical harm, terrorism, trafficking, or other serious unlawful conduct may be prioritized.

Freemedia may preserve or disclose relevant information to competent authorities or child-protection organizations where required or permitted by law.

25. Changes to this Privacy Policy

Freemedia may update this Privacy Policy to reflect changes in:

  • The Services or platform features.
  • Data-processing practices.
  • Service providers or infrastructure.
  • Security practices.
  • Applicable law or regulatory requirements.
  • Business operations.

When changes are made, Freemedia will update the Effective Date and version number.

Where required by applicable law, Freemedia will provide additional notice through the Services, email, or another appropriate channel and will request consent where the change requires consent.

Continued use of the Services after an updated policy takes effect does not override rights or consent requirements that apply under law.

26. Contact Us

Questions, concerns, complaints, and privacy-rights requests may be submitted to:

Trade to Travel Inc.

Trinity Chambers P.O. Box 4301 Road Town, Tortola British Virgin Islands

Privacy Contact: Leah Privacy and legal enquiries: leah@tradetotravel.com

Support, account deletion, and reporting: rachel@tradetotravel.com

Users may also contact Freemedia through the support functionality available within the Services.

If you are not satisfied with Freemedia’s response, you may have the right to complain to the privacy or data-protection authority in your jurisdiction.

27. International Users

Freemedia is available in multiple countries. Privacy rights and obligations may vary according to the country or region in which a user lives.

Nothing in this Privacy Policy limits rights that cannot legally be restricted. Where applicable law provides greater protection than this Privacy Policy, Freemedia will apply that protection to the extent required.

Freemedia may provide supplemental regional privacy notices where necessary. A regional notice forms part of this Privacy Policy for users to whom it applies.

28. No Sale of Personal Information or Behavioural Advertising

Freemedia does not:

  • Sell personal information for monetary consideration.
  • Share personal information for cross-context behavioural advertising.
  • Display third-party behavioural advertising.
  • Use third-party advertising trackers.
  • Track users across unrelated applications or websites for advertising purposes.

If Freemedia’s business model changes in the future, this Privacy Policy and the relevant app-store declarations will be updated before such processing begins, and consent or opt-out controls will be provided where required by law.

29. Browser and Device Privacy Signals

Because Freemedia does not sell personal information or use cross-context behavioural advertising, it does not currently process browser “Do Not Track” signals for advertising opt-outs.

Where Freemedia is legally required to recognize a supported universal opt-out mechanism, such as Global Privacy Control, it will do so for the processing to which that signal applies.

30. Governing Privacy Principles

Freemedia is committed to processing personal information in accordance with the following principles:

  • Lawfulness, fairness, and transparency.
  • Purpose limitation.
  • Data minimization.
  • Accuracy.
  • Storage limitation.
  • Integrity and confidentiality.
  • Accountability.

We continually review our privacy practices and security measures to help ensure that personal information is handled responsibly and in accordance with applicable legal requirements.