Privacy policy

Freezbone Privacy Policy — Europe

eu.freezebone.com · Effective date: 1 January 2026 · Version 1.0

This Privacy Policy explains how Freezbone Limited and its affiliates (“Freezbone”, “we”, “our”, “us”) collect, use, share and protect your personal data when you visit eu.freezebone.com, use our mobile applications, sign up for our email or text messaging programmes, submit reviews, apply for a job, or otherwise interact with us (together, the “Services”).

It applies to individuals in the European Economic Area (EEA), the United Kingdom and Switzerland, and is written to comply with the EU General Data Protection Regulation (“GDPR”), the UK GDPR, the Swiss Federal Act on Data Protection, and applicable ePrivacy rules. We process your personal data only as described in this Policy and only where we have a lawful basis to do so. Nothing in this Policy is, or requires, your agreement — your rights under data protection law apply regardless.

Contents

1.Who we are & how to contact us

The controller of your personal data is:

Freezbone Limited — registered in Ireland, company registration no. 806716
The Black Church, St. Mary's Place, Dublin 7, D07 P4AX, Ireland
Email: team@freezbone.com (subject line: “Privacy”)

Because we are established in Ireland, our lead supervisory authority under the GDPR is the Irish Data Protection Commission (see Section 18).

2.Personal data we collect

Data you give us

Identity & contact data — name, email address, postal and shipping address, telephone number.
Order data — products purchased, returned or cancelled, items in your basket, delivery details. Payment card details are collected and processed directly by our PCI-DSS-compliant payment processors; we never store full card numbers.
Account data — login credentials, preferences and settings.
Pet data — your pet's name, breed, gender, birthdate, size, weight, health information and photos, where you choose to provide them.
Communications — messages you exchange with customer service, and the content and metadata of texts sent or received through our messaging programme.
Content you submit — reviews, photos, videos, survey answers, and entries to contests or promotions.

Data collected automatically

When you use the Services we collect device and usage data: IP address, device type and identifiers, browser and operating system, pages viewed, referring site, date, time and duration of visits, and approximate (IP-based) location. Non-essential collection happens only through cookies and similar technologies with your consent — see Section 5. We do not collect precise geolocation from your device without your separate, explicit opt-in.

Data from other sources

We receive limited data from payment processors (payment confirmation, fraud signals), delivery carriers (delivery status), social media platforms (where you interact with our content or log in through them, subject to your settings on that platform), and fraud-prevention providers. We do not buy personal data about you from data brokers for our European Services.

3.Purposes & legal bases

We process your personal data only for the purposes below, and only on the corresponding legal basis under Article 6 GDPR / UK GDPR. Where we rely on legitimate interests, we have balanced those interests against your rights and will provide details of the assessment on request.

Purpose	Data used	Legal basis
Fulfilling your orders — payment, delivery, returns, refunds	Identity, contact, order data	Performance of a contract (Art. 6(1)(b))
Customer service and responding to enquiries	Identity, contact, order data, communications	Performance of a contract; legitimate interest in resolving your queries (Art. 6(1)(f))
Service messages — order status, recalls, changes to terms or this Policy	Identity, contact data	Performance of a contract; legal obligation (Art. 6(1)(c)) for recalls and safety notices
Email and SMS marketing	Identity, contact, order data	Consent (Art. 6(1)(a)); or, for email to existing customers about similar products, legitimate interest under the “soft opt-in” where national law permits — always with a free opt-out
Personalised advertising, analytics, cross-device measurement	Device and usage data, order data	Consent (Art. 6(1)(a)), given via our cookie banner and withdrawable at any time
Essential site operation, load balancing, basic security logs	Device and usage data	Legitimate interest in running a secure, functioning service (Art. 6(1)(f))
Fraud prevention and enforcing our terms	Identity, order, device data	Legitimate interest in preventing fraud and abuse; legal obligation where applicable
Product and service improvement using aggregated or de-identified data	Usage and order data (aggregated)	Legitimate interest; where data is truly anonymised it is no longer personal data
Contests, sweepstakes, surveys and research	Identity, contact data, your entries	Consent; performance of a contract (the promotion's terms)
Marketing use of reviews, photos and videos	Content you submit, first name & last initial, likeness	Consent given at submission (Art. 6(1)(a)) — see Section 6
Compliance with law, responding to lawful requests, defending legal claims	Any of the above, as required	Legal obligation (Art. 6(1)(c)); legitimate interest in defending our rights

Pet health information you share is treated as ordinary personal data about you (the owner). We do not process special-category data about you and do not ask for it — please do not include health or other sensitive information about yourself in reviews or messages.

4.Marketing — email & SMS

Opt-in first. We send you marketing emails or text messages only if you have actively opted in, or — for email only — if you are an existing customer, the message concerns similar products, and you were given a clear chance to refuse when we collected your address (the “soft opt-in”, where national law permits it).
Consent is never a condition of purchase. You can buy from us without agreeing to any marketing.
SMS programme. Messages may be sent using automated technology. Message and data rates may apply per your mobile plan. We collect message metadata (time and date sent or received) and message content to operate the programme.
Opting out is one step and free. Reply STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any text; use the unsubscribe link in any email; or email team@freezbone.com. We apply opt-outs promptly — at the latest within the period required by law — and you will continue to receive only transactional messages (order status, recalls, administrative notices).
Withdrawing consent does not affect the lawfulness of processing before withdrawal.

5.Cookies & similar technologies

We use cookies, pixels, SDKs and similar technologies (“cookies”) on the Services. On your first visit, our consent banner lets you accept all, reject all, or choose by category — with reject as easy as accept. We set non-essential cookies only after you consent, and you can change or withdraw your choices at any time via the “Cookie Settings” link in the site footer.

Category	What it does	Basis
Strictly necessary	Sign-in, basket, checkout, security, consent storage	Exempt from consent (essential for the service you request)
Functional	Remembers preferences such as language and region	Consent
Analytics	Measures how the Services are used so we can improve them	Consent
Advertising	Personalised ads on our Services and elsewhere; ad measurement; social media pixels	Consent

A full list of the cookies we use, their providers and their lifespans is available at any time via the “Cookie Settings” link in the site footer. If you reject non-essential cookies, the Services remain fully usable; only personalisation and measurement are affected.

6.Reviews, photos & customer content

If you submit a review, photo or video of your pet or our products, we may — only with the consent you give at the point of submission — use that content, together with your first name and last initial, in our marketing on our websites, social media, paid advertisements and email campaigns. Photos and videos that include your likeness are personal data and are handled under this Policy.

You may withdraw this consent at any time by emailing team@freezbone.com. We will stop using your content in new and future marketing materials and remove it from channels under our control without undue delay. Anything you post in public areas of the Services (for example, a product review page) is visible to other visitors.

7.Who we share your data with

We do not sell your personal data, and we do not share it with third parties for their own independent marketing. We share it only:

With our affiliates, for the purposes in Section 3, under intra-group data protection terms.
With processors acting on our instructions — order fulfilment and delivery, payment processing, email and SMS platforms, phone carriers, customer service tooling, hosting, analytics, security and fraud prevention. Each is bound by a contract meeting Article 28 GDPR: they may use your data only to provide services to us, must keep it confidential and secure, and must delete or return it when the engagement ends.
With advertising and social media partners — only where you have consented via our cookie banner (Section 5).
Where the law requires it — to comply with a legal obligation, a court order, or an enforceable request from a competent authority, or to establish, exercise or defend legal claims, protect our rights and property, or protect the safety of our customers or others. We assess every such request and disclose the minimum necessary.
In a business transfer — if Freezbone or its assets are involved in a merger, acquisition, restructuring or insolvency, your data may be transferred to the successor, which remains bound by commitments at least as protective as this Policy. We will notify you of any such change in control that affects your data.

8.International transfers

The Freezbone group operates from the United States, so your personal data will be transferred to and processed in the US, and may be processed in other countries where our processors operate. Whenever your data leaves the EEA, the UK or Switzerland, we protect it with at least one of the following safeguards:

a transfer to a recipient certified under the EU–US Data Privacy Framework (or its UK Extension / Swiss–US DPF), where applicable;
the European Commission's Standard Contractual Clauses, supplemented by the UK International Data Transfer Addendum and Swiss amendments where required, together with additional technical and organisational measures identified in transfer risk assessments; or
a country the European Commission (or UK/Swiss authorities) has found to provide adequate protection.

You can obtain a copy of the relevant safeguards by contacting team@freezbone.com.

9.How long we keep your data

We keep personal data only as long as necessary for the purpose it was collected for, and then delete or irreversibly anonymise it. We never keep data simply because it might be useful someday.

Data	Retention period
Order and transaction records	Duration of the contract, then as required by tax and accounting law (typically 6–10 years depending on country)
Account data	While your account is active; deleted or anonymised within 24 months of account closure
Marketing consents and contact data	Until you withdraw consent or opt out; suppression records (the minimum needed to honour your opt-out) are kept indefinitely
SMS programme data	While you are subscribed, plus 12 months for compliance evidence
Customer service correspondence	3 years from resolution of the enquiry
Reviews and customer content used in marketing	Until you withdraw consent
Cookie data	Per the lifespans in our cookie settings; consent records kept as evidence of compliance
Job applicant data	Duration of the recruitment process, plus 12 months with your consent for future roles
Legal claims and disputes	Until the claim and any appeal period is exhausted

10.Security

We apply technical and organisational measures appropriate to the risk, including encryption of data in transit, access controls on a need-to-know basis, vendor security reviews, and staff confidentiality obligations. Payment card data is handled by PCI-DSS-compliant processors. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours of becoming aware of it and, where the risk is high, notify you directly without undue delay.

11.Your rights

You have the following rights over your personal data. They are free of charge, and we will never penalise or disadvantage you for using them.

Access — obtain confirmation that we process your data, a copy of it, and the supporting information in Article 15 GDPR.
Rectification — have inaccurate data corrected and incomplete data completed.
Erasure — have your data deleted where it is no longer needed, you withdraw consent, you object and we have no overriding grounds, or it was processed unlawfully.
Restriction — require us to store but not otherwise use your data while a dispute about it is resolved.
Portability — receive the data you provided to us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible.
Objection — object at any time to processing based on legitimate interests; we will stop unless we demonstrate compelling legitimate grounds that override your rights. If you object to direct marketing, we stop — no exceptions, no justification required.
Withdraw consent — at any time, as easily as you gave it, without affecting prior processing.
Automated decisions — not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects (see Section 13).

12.Exercising your rights

Email team@freezbone.com with the subject “Privacy Rights Request”, or write to the address in Section 1. You may also use an authorised agent or exercise the rights of someone you legally represent.

We respond within one month. For complex or numerous requests we may extend by up to two further months, and will tell you within the first month if so, with reasons.
We may ask for information reasonably necessary to confirm your identity — normally confirming the email address or phone number we hold for you. We ask only for what verification requires.
If we refuse a request in whole or part, we will tell you why and inform you of your right to complain to a supervisory authority and to a judicial remedy.

13.Automated decision-making

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you. We use automated fraud screening on orders, but any order declined by automated screening is subject to human review on request. Profiling for advertising happens only with your consent (Section 5) and you can withdraw it at any time.

14.Children

The Services are directed at adults and are not intended for children. We do not knowingly collect personal data from anyone under 16 (or the lower age, not below 13, set by your country for information society services). If you believe a child has provided us personal data, contact team@freezbone.com and we will delete it promptly.

15.Job applicants

If you apply for a role with Freezbone from the EEA, UK or Switzerland, we process the identity, contact, employment-history and education data you provide in order to assess your application (steps prior to entering a contract, Art. 6(1)(b)) and to comply with legal obligations. Background checks are conducted only where and to the extent permitted by the law of your country, and you will be informed beforehand. Applicant data is retained per Section 9. A role-specific privacy notice may be provided during recruitment and takes precedence for that process.

16.Third-party links

The Services may link to third-party websites and services we do not control, and you may interact with us on social media platforms that act as their own controllers for the data they collect. This Policy does not apply to those third parties — review their privacy notices before providing data.

17.Changes to this Policy

We may update this Policy from time to time. We will post the updated version here with a new effective date and, for material changes, give you clear advance notice (for example by email or a prominent site notice) before the changes take effect. Where a change requires your consent — for example, a new purpose incompatible with the original one — we will ask for it; continued use of the Services is not treated as consent.

18.Complaints

If you are unhappy with how we handle your personal data, contact us first at team@freezbone.com — we take every complaint seriously and aim to resolve it directly. You also have the right, at any time, to lodge a complaint with your local supervisory authority:

Ireland (our lead supervisory authority): the Data Protection Commission, dataprotection.ie
EEA: the data protection authority of your country of residence, workplace or where the alleged infringement occurred (directory: edpb.europa.eu)
UK: the Information Commissioner's Office (ICO), ico.org.uk
Switzerland: the Federal Data Protection and Information Commissioner (FDPIC)

You may also seek a judicial remedy against us or against a supervisory authority's decision.

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