HU WENTAO, trading as Frely, operates the Frely software service as an individual merchant in Hong Kong and controls personal data used for its account, platform, billing, security, support, and service records. A selected model provider, capability provider, payment provider, or analytics provider can act as a separate controller or processor for data sent to that provider.
Privacy requests may be sent to [email protected].
Frely can collect an email address, account identifiers, profile data, team membership, roles, authentication records, device-authorization records, session records, and security events. Password records use password hashes rather than readable passwords.
Frely can collect product identifiers, listing identifiers, purchase identifiers, order references, payment-provider identifiers, amount, currency, payment status, refund or reversal facts, credit balance events, entitlement facts, billing records, and settlement records. Waffo Pancake handles payment-method data for new hosted checkout transactions. Frely does not need a full payment-card number for its product records.
Frely can collect API request identifiers, model or capability selection, plan source, usage units, token counts, cost records, timestamps, response status, error codes, routing facts, and service-health facts.
Frely processes prompts, files, tool inputs, request bodies, model inputs, capability inputs, outputs, and responses when the requested service needs that content. Request Capture can store request and response content when capture is enabled. Capture archives use access controls and integrity checks.
Frely can collect IP address, request headers, user agent, browser data, device data, timestamps, host information, rate-limit facts, abuse signals, and security logs.
The Frely website and Web console can use Microsoft Clarity session analytics. Clarity starts after analytics consent. Frely configures Clarity analytics storage as granted after consent and advertising storage as denied. A user can reject analytics or withdraw consent through Analytics settings.
After analytics consent, Frely also remembers how a visitor first arrived: campaign tags in the link (such as utm_source), a referral username, the referring website's host name, and the first page visited. Frely does not store the full referring address. If the visitor creates an account within 30 days, Frely saves this source with the new account to learn which channels bring users. Frely does not use it for advertising and does not share it with advertising providers.
Anyone can apply to become a Frely Insider. Frely then stores the email address, the answers to the short questionnaire (fixed choices and an optional note), the page language, and the application status. Frely uses them to review the application and to email the confirmation and the Insider link, and not for other marketing email. Applicants who say they are a KOL also give their main platform, a link to their public profile and a follower range, and receive a verification code by email to place on that profile; Frely uses these only to check that the profile belongs to the applicant, and clears the profile link and the code 90 days after the review.
Frely can collect messages, attachments, diagnostic information, and account references supplied in a support request.
Frely uses personal data to:
The legal basis can include contract performance, legitimate interests in security and service operation, consent for analytics, and legal obligations. The basis depends on the user's location and the processing purpose.
Frely does not sell personal data.
Frely can share data with:
Frely sends a provider the data needed for the selected service. Provider terms can apply to the provider's processing.
Frely can use essential cookies or storage for authentication, security, preferences, and service state. The website and Web console store the analytics consent choice in local storage. Clarity analytics storage and the first-visit source cookie (frely_src, up to 30 days, removed once saved with a new account or when consent is withdrawn) are used only after consent. Advertising storage stays disabled under Frely's Clarity configuration.
Frely keeps data according to the record type and service contract:
An archive can preserve a record after removal from hot storage. A retention window for hot storage is not a promise of full deletion from every archive, audit record, backup, or legally required record.
Frely uses access controls, credential separation, redaction, bounded logs, encrypted transport, audit records, integrity checks, and controlled archive processes. No system can guarantee absolute security.
Frely will make breach notifications within the period required by applicable law. A law that requires a 72-hour regulator notice will receive that timetable after Frely determines that the event meets the reporting threshold.
Frely, a payment provider, a model provider, a capability provider, an analytics provider, or an infrastructure provider can process data in a country outside the user's country. Frely uses the provider contract, applicable transfer mechanism, access controls, and service configuration required for the transfer.
Applicable law can give a user rights to access, correct, delete, restrict, object to, or receive a copy of personal data, and rights to withdraw consent. A request may be sent to [email protected]. Frely can request information needed to verify the requester and protect another user's data.
A deletion request does not require deletion of a record that Frely must retain for payment, accounting, security, fraud prevention, dispute, legal, audit, or archive obligations.
Frely is not intended for people under 18. Frely does not offer accounts to children under 18. A report concerning a minor's data may be sent to [email protected].
Frely can link to third-party services. Their privacy terms govern data that a user sends to them outside Frely's control.
A material Privacy Policy change will receive a new effective date and version on this page. The Service can provide an account notice for a change that affects user rights or material data use.
The Frely Terms of Service govern Service use, purchases, acceptable use, and product obligations.
Privacy and data-rights inquiries: [email protected].