Privacy Policy

ARCHIVED 2025-12-01, DATE APPROXIMATE · VERSION 20251201_rev01 · COMPARED WITH 20250701_rev01

Full text changes — 20250701_rev01 to 20251201_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 **Personal data processed:** The data provided in the image rights transfer document - name, surname, identity card or equivalent and address - are only processed for the purposes of regulatory compliance verification and are not included in the processing of machine learning or AI model training.
 Your image and/or voice may be used for purposes of development, training, testing, or improvement of software, algorithms, and machine learning and artificial intelligence models in combination with other images, texts, graphics, films, audios, and audiovisual works, always in an aggregated form, without the processing pursuing or making it possible to uniquely identify you.
 **Personal data processed:** Your image or voice incorporated into our content.
+Your image or voice incorporated into our content is publicly communicated worldwide through the internet -our Services- and is transferred to third parties in the form of licenses or access to the content. These international data transfers are made to countries with a level of personal data protection lower than that provided for in the GDPR, under the exception in Article 49(1)(a) of the GDPR.
+Your image or voice incorporated into our content is publicly communicated worldwide through the internet -our Services- and is transferred to third parties in the form of licenses or access to the content.
 ##### 3.5. Personalized advertising on Freepik and other websites
 We promote our products:
 \- **with social networks and other platforms users, between profiles of potential Freepik users**, using audience segmented by interests, not created by Freepik but already offered by platforms such as Pinterest, Google and X (Twitter in its old name) and hired by Freepik for this purpose. Likewise, we can only identify you if you register as an user.
 Our lawful base is our legitimate interests of getting new clients through personalized advertising of our products through profiling offered by social media and other platforms.
 **Personal data processed**: We select the groups of users to whom advertising will be displayed based on the segments offered by the platforms, such as age ranges or country. These platforms provide us with aggregated information about the performance of each campaign, but we cannot identify the specific users who have become registered users as a result of it.
 \- through **retargeting**: impacting visitors who have visited and left our Services without registering, when they have accepted the use of our cookies, and these allow us to display advertising to them on third party websites.
+In this case, our basis of legitimacy is your **consent** (given both on our Services as on third party websites where the advertising is displayed). You can find more information about this treatment in our [Cookie Policy.](https://freepik.com/legal/cookies)
+In this case, our basis of legitimacy is your **consent** (given both on our Services as on third party websites where the advertising is displayed). You can find more information about this treatment in our [Cookie Policy.](https://ff5ef4b4a2defe38f504d5d04f54db457bada35eda2c1d474a9557e-apidata.googleusercontent.com/legal/cookies)
 ##### 3.6. Sending of commercial communications by email
 We will send you electronic commercial communications if (i) you have registered or contracted any of the Services, (ii) you request information about our products through any of the forms for this. In any case, we will do so as long as you have not expressed your objection to receiving such communications (you can do this conveniently via the specific slider in your user profile, as well as in each communication you receive, at the bottom, via the "Unsubscribe" button).
 We will also send you content updates from the creators you follow, provided that you have specifically consented to this via the specific choice on your user profile. You can revoke your consent by unchecking it.
 Our legal basis is our **legitimate interest** (to offer you commercial information about products or services similar to those that you have already contracted or about which you have requested information), by virtue of art. 21.2 of Law 34/2002 of July 11, of Information Society Services and Electronic Commerce (LSSI).
 ##### 3.7. Advertisements on our Services
+Unless you become a premium user, we will display personalized advertisements on our Services, if you consent the installation of cookies (more information in our [Cookies Policy](https://freepik.com/legal/cookies)).
+Unless you become a premium user, we will display personalized advertisements on our Services, if you consent the installation of cookies (more information in our [Cookies Policy](https://ff5ef4b4a2defe38f504d5d04f54db457bada35eda2c1d474a9557e-apidata.googleusercontent.com/legal/cookies)).
 When we use cookies, we do so based on your prior **consent**. You can accept or reject all our cookies or select them granularly, through our One Trust CMP (our cookie setting panel).
 ##### 3.8. Personalized advertising through preference forms
 We offer voluntary surveys to learn about your basic user profile and preferences, in order to personalise your experience in our Services as well as the advertising we show you or the information of interest that we send you, based on the profile in which you place yourself.
 Likewise, based on our legitimate interest to know your opinion in order to improve our products' performance and usability, we may contact you to request your opinion and preferences through satisfaction surveys.
 In addition, based on our legitimate interests (improving our products, increasing our sales) we offer you to participate in surveys in order to learn first-hand about your opinions and preferences about our products and, on that basis, to eliminate friction, facilitate their use and improve your interactions with them.) Therefore, we will contact you to ask for your opinion through satisfaction surveys.
 **Personal data processed:** contact information.
+##### 3.10. Support requests
+##### 3.10.1. AI assistant customer support
+When you contact us requesting information, support or feedback, we process your data in order to assist you, based on your **consent** expressed in your own request.
+Similarly, based on your explicit consent provided by clicking the acceptance buttons, our AI assistant will process your data for the same purposes of support and information requests. The AI assistant operates through the fully automated analysis and comparison of your request and responses with a database generated from frequently asked questions, your account data, and predefined customer-support rules.
+If you believe that the assistant's response is unsatisfactory or prejudicial, or if it is unable to provide you with a satisfactory answer or solution, you may challenge the decision or lodge a complaint at [support@freepik.com](mailto:support@freepik.com). Our human supervisor team will take into account any additional details and context you submit with your complaint before reaching a final decision.
+**Personal data processed:** content of your request, username, email address registered with Freepik, language preference, browser, time zone, and operating system.
+**Description of the logic involved:** The AI assistant analyses your query using natural language processing and predefined rules to identify its topic and provide the most suitable response from our knowledge base.
 **Personal data processed:** contact information that you provide us with in order to respond to your request and the content of your request.
 ##### 3.11. Submitting your resume
 When you apply to join the Freepik team or as a freelance designer or collaborator, we process your personal data on the basis of your **consent**, in order to assess your recruitment.
 Also, such data is used for security purposes against any type of attack or fraudulent or illegitimate use of the same, based on our legitimate interest to maintain the security, integrity and resilience of our systems and ensure the regular provision of the service, and to comply with our agreements and protect our assets.
 You may deactivate or unsubscribe at any time and may exercise your privacy rights, in particular your right to object, by contacting us at the address given in the specific section of this policy.
 ##### 3.14. AI-based products.
+We offer various AI-based products to generate images based on your Inputs or your own image, or images that you consent to upload to our platform. We will handle your data for the following purposes:
+We offer various AI-based products to generate images based on your Inputs or your own image, or images that, under your responsibility, upload to our platform. When you provide us with content that includes personal data of third parties (image, voice, identifiers in your prompt), you do so under your own responsibility, and you must inform the interested parties and have a legal basis for processing it (consent or another basis). We will handle your data for the following purposes:
 - Provide our Service in accordance with our terms and conditions and usage policy, based on the existing contract between the parties.
+- Generate avatars or recreations based on your own image, if you upload or capture your image with your camera, or on other images you decide to upload, based on your consent.
+- Generate avatars or recreations based on your own image, if you upload or capture your image with your camera, or on other images you decide to upload, based on your responsibility.
 - Maintain the security of our products and systems, based on our legitimate interests.
+- Improve our products, including user experience and the training and enhancement of our artificial intelligence models, limited to the **Inputs** you provide when using our AI-based products, as well as the **Outputs** generated as a result, based on our legitimate interest. **In no case will we use your own image or the images you upload to train or improve our artificial intelligence models in order to provide the Services.**
+- Improve our products, including user experience and the training and enhancement of our artificial intelligence models. Processing for this purpose is limited to the **Inputs** (instructions or prompts) you provide when using our AI-based products, as well as the **Outputs** generated as a result, based on our legitimate interest. **In no case will we use your own image or the images you upload to train or improve our artificial intelligence models in order to provide the Services.**
 - The rest of the data processing mentioned in section 3.2, in their respective cases, applies if you are a registered user.
 Additionally, in no case do these data processing activities aim to uniquely identify you.
 **Personal data subject to processing:**
 ##### 3.15. Legally binding processing.
 In some cases we are **legally bound** by different regulations (regardless of whether or not you give your consent), to process and / or transfer certain personal data to different entities. For example, to the Tax Authority, or the law enforcement authorities, at their request.
 **Personal data processed:** those set forth in the applicable regulations.
+#### 3.16. Enterprise or Professional Plans
+When Freepik provides access to its API or AI-powered tools to Licensees under an enterprise or professional plan, it may process, on behalf of those Licensees and their Authorized Users, and strictly under their instructions, personal data that the Licensee or their Authorized Users may voluntarily include in their Inputs (for example, text, images, or videos that contain personal data of third parties). In those cases, Freepik acts as Data Processor, and the Licensee remains the Data Controller, in accordance with the applicable Data Processing Agreement (DPA) in each case.
+Freepik processes such data only to provide the contracted services, ensuring appropriate technical and organizational security measures. It does not use these Inputs or Outputs for its own purposes or to train its models. Likewise, the Licensee assumes the obligation to provide information regarding data protection before processing such data.
+**Personal data processed:** content included by the Licensee or their Authorized User in their Inputs (which may incidentally contain third-party identifiers such as name, image, voice, or contact details).
 #### 6\. Disclosure of personal data
 ##### Access by third parties providing services to us
 We may disclose personal data of our Users to third parties only in cases when it is strictly necessary for Freepik Company to perform their functions and to comply with the relevant Terms of Use of each Service. We may also share personal information with other third parties to ensure compliance with applicable laws, including:
 These services provided by third parties are necessary for the development of Freepik Company's business activity. The processing of personal data is at all times subject to a contract which establishes the duties of the data processor towards the data controller (us). Under no circumstances will personal information be used for other purposes and it will be managed in compliance with Freepik Company policy guidelines, their privacy policy and the applicable data protection regulation.
 In accordance with our commitment to your privacy and your data protection right, we exclusively choose only top-tier service providers, leaders in their respective sectors. You can request the list of providers that have access to your personal data, as well as the services provided by each one, through the email address provided in the exercise of rights section.
 We commercially exploit the advertising that is shown to you on our Services by third parties, and we do so through "cookies" and other similar technologies, always with your prior consent, collected through the One Trust CMP (the configuration panel of cookies that informs you of the different purposes of data processing developed by the advertising companies, among others).
+You can find the complete information in our [Cookies Policy](https://freepik.com/legal/cookies).
+You can find the complete information in our [Cookies Policy](https://ff5ef4b4a2defe38f504d5d04f54db457bada35eda2c1d474a9557e-apidata.googleusercontent.com/legal/cookies).
 Our Services also includes plugins which allow the User to carry out actions on social networks of third parties such as X or Pinterest, like, for instance, sending a publication or showing support to the Services. These plugins are indicated with the corresponding social network logotype, and require the login credential to the correspondent platform, and your consent.
+If you accept these plugins, the content will be transferred to the corresponding social network. You can find in our [Cookies Policy](https://freepik.com/legal/cookies) links to the privacy statements of these social networks.
+If you accept these plugins, the content will be transferred to the corresponding social network. You can find in our [Cookies Policy](https://ff5ef4b4a2defe38f504d5d04f54db457bada35eda2c1d474a9557e-apidata.googleusercontent.com/legal/cookies) links to the privacy statements of these social networks.
 ##### Data flows within the Freepik Group of Companies
 The Freepik Company Group of Companies, in order to centralise administrative and business infrastructure functions and to benefit from the functional specialisation and compartmentalisation inherent in these corporate structures, will process personal data within the group of suppliers, users and employees based on our legitimate corporate interests.
 Depending on the case, this processing is mainly carried out as a processor and, exceptionally, as a joint controller (for the execution of strategic decisions of the Group).