Privacy Policy

Last updated: 26 May 2026

This Privacy Policy explains how Freeholder collects and handles your personal data. Freeholder is a trading name of Crescent Code Limited, a company registered in England and Wales with its registered office at 7 Bell Yard, London WC2A 2JR. In this policy, "we", "us" and "our" refer to Crescent Code Limited.

We are the "data controller" of the personal data we collect about you, within the meaning of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

1. What we collect and why

1.1 Information you give us

When you buy a product, you provide (via Paddle's checkout) your name, email address, billing address, and payment details. We need this information to fulfil your order, send you the product, and meet our legal obligations (such as keeping tax and accounting records).

When you contact us — by email or any other means — we receive whatever you choose to send us, along with your email address.

1.2 Information we receive automatically

When you visit freeholder.dev, our hosting provider's standard server logs record technical request data: your IP address, the page you requested, the time of the request, your browser type, and the referring page. We use this to operate the site, diagnose problems, and protect against abuse.

Our software products may include limited diagnostic telemetry (for example, crash reports). Where this is the case, the product's documentation will explain exactly what is collected and how to turn it off.

1.3 Cookies

freeholder.dev uses only the cookies strictly necessary for the site and our checkout to function. We do not use advertising or third-party analytics cookies. If this changes, we will update this policy and seek your consent where required.

2. Our lawful bases

Under the UK GDPR, we rely on the following lawful bases:

• Performance of a contract — to take payment for, deliver, and support the product you bought.
• Legal obligation — to keep records required by UK tax and company law.
• Legitimate interests — to keep the site secure, prevent fraud, respond to your enquiries, and improve our products. We balance our interests against your rights and freedoms.
• Consent — for anything else that requires it (for example, optional marketing emails, if and when we offer them). You can withdraw consent at any time.

3. Who else handles your data

We use a small number of carefully selected service providers ("processors") to operate Freeholder. They process your data only on our instructions and under written contracts.

• Paddle.com Market Limited (United Kingdom) — payment processing, Merchant of Record, invoicing, tax compliance, and fraud screening.
• Cloudflare, Inc. (United States) — DNS, CDN, and protection against malicious traffic.

Paddle acts as a separate data controller for the payment portion of your transaction. Its privacy notice is at paddle.com/legal/privacy.

4. International transfers

Some of our processors are based outside the United Kingdom. Where personal data is transferred outside the UK, we rely on appropriate safeguards under the UK GDPR — typically UK Government adequacy decisions, the International Data Transfer Agreement, or Standard Contractual Clauses with the UK Addendum, as applicable.

5. How long we keep your data

We keep your purchase and contact records for as long as needed to provide the product, handle refunds and support, and meet our legal obligations (in the UK this is typically six years for tax and accounting records). Server logs are kept for a short period and then deleted or anonymised.

6. Your rights

Under the UK GDPR you have the right to:

• Be informed about how your data is used (this policy).
• Request a copy of the personal data we hold about you.
• Have inaccurate data corrected.
• Ask us to delete your data ("right to erasure"), where applicable.
• Ask us to restrict processing in certain circumstances.
• Object to processing based on our legitimate interests.
• Receive your data in a portable format, where applicable.
• Withdraw consent at any time, where we rely on consent.

To exercise any of these rights, email privacy@freeholder.dev. We will respond within one month.

If you are unhappy with how we have handled your data, you can complain to the UK Information Commissioner's Office at ico.org.uk or on 0303 123 1113. We would, however, appreciate the chance to address your concerns first.

7. Children

Our products are not directed at children under 13, and we do not knowingly collect personal data from them. If you believe we have, please contact us and we will delete it.

8. Security

We take reasonable technical and organisational measures to protect your data, including encryption in transit (HTTPS), access controls, and the use of reputable processors. No system is perfectly secure, but we work to keep risk low.

9. Changes to this policy

If we change this policy, the new version will appear at freeholder.dev/privacy with an updated "Last updated" date. Material changes will be flagged on the site.

10. Contact

Crescent Code Limited, trading as Freeholder
7 Bell Yard, London WC2A 2JR, United Kingdom
Email: privacy@freeholder.dev