Privacy notice

Last updated: 13 October 2026

This page explains what personal data we collect when you visit freelime.app, join the Freelime waitlist or email us, why we collect it, who has access to it, and the rights you have over it. We keep this short and in plain English on purpose — if anything is unclear, write to freelime@esmhconsulting.com.

1. Who is responsible for your data

The data controller for this website and the Freelime waitlist is:

E.S.M.H Consulting FZE
Al Shmookh Business Center, One UAQ
UAQ Free Trade Zone
Umm Al Quwain, United Arab Emirates
License No.: 8630
Represented by: Max Roeck
Email: freelime@esmhconsulting.com

See also the Legal Notice.

2. What data we collect

We only collect the data you actively give us, plus minimal technical data needed to serve the site. If you open the waitlist form, Whop and the services it uses also receive technical data from your browser and store identifiers in it, as described in 2.2 and 2.5.

2.1 Technical data your browser sends automatically

This website is hosted by RoeckNet Webhosting. Like every website, our hosting provider's server automatically receives standard request information: your IP address, your browser and operating system, the page you requested, the page you came from, and the date and time. This is used solely to operate the site, prevent abuse, and diagnose errors. It is not combined with the details you give us, and it is rotated out of the host's logs on a short rolling schedule (see section 6).

2.4 Emailing us

If you email us, we receive your email address and whatever you write. We use it to answer you and to act on your request, for example to remove you from the waitlist. Our address is an alias of our Google Workspace mailbox, so Google handles the messages (see section 4). When we write to you, we do so by email, either through Whop or from an E.S.M.H Consulting email address; in the second case, Google handles the message too.

2.5 Cookies and tracking

Until you open the waitlist form, this website sets no cookies, stores nothing in your browser, and uses no analytics or tracking tools. It uses your device's system fonts, so no font service or other third party is contacted when you load a page.

Once you open the form, Whop's script runs on this page and sends usage events about the form to Whop (see 2.2), and Whop and the services it uses store identifiers in your browser:

• On this website's domain (set by Whop's script): the cookies whop_anonymous_id (kept for 1 year) and _whop_ssk (less than half an hour), and a device ID, _whop_device, in local storage.
• On the services' own domains (set by the services themselves), for security, fraud prevention and bot protection: Cloudflare's __cf_bm (about 30 minutes); hCaptcha's hmt_id (30 days) and __cflb; Stripe's m (up to 2 years); HUMAN's _pxvid (1 year), _px3, _pxde and pxcts; and a device token from Sardine (1 year).

You can delete all of these in your browser's settings, under the stored data for this website and for these services. Whop can change its form and the services it uses at any time. We check this list when we update this notice.

3. Why we use your data and on what legal basis

We process your data on the legal bases set out in Article 6 of the EU General Data Protection Regulation (GDPR), which we apply as a baseline for all visitors regardless of where they live:

• To load the waitlist form and the cookies and local storage it sets on your device — Article 6(1)(a) (consent), given by clicking “Show the sign-up form”. See Your consent in 2.2.
• To keep your waitlist entry and email you about Freelime and the waitlist — Article 6(1)(a) (consent), given by submitting the form. We use your email address only to tell you about Freelime and the waitlist, for example if Freelime is released, and your optional answers to decide whether to release Freelime and how to price it.
• To operate and secure the website (the host's server logs) — Article 6(1)(f) (legitimate interest in running a working, secure website).
• To answer your emails — Article 6(1)(f) (legitimate interest in replying to you).

We do not use your data for advertising, profiling, or automated decision-making. We only email you about Freelime and the waitlist, and we use the optional answers only to decide whether to release Freelime and how to price it. The automated fraud and bot checks that Whop's service providers run on the form are described in 2.3.

4. Who else handles your data

We use a small number of third-party services to run the site and the waitlist. RoeckNet Webhosting and Google process data on our behalf under written data-processing terms. Whop provides the waitlist form and stores the entries for us, and also acts under its own terms and privacy policy.

• RoeckNet Webhosting — serves the static files of this website and processes basic request logs (see 2.1) on a short rolling retention window. The website runs on a server rented from STRATO in Germany.
• Whop (whop.com (opens in a new tab)) — provides the waitlist form and stores the entries for us. Whop also acts under its own terms and privacy policy (opens in a new tab): it uses some data for its own purposes, and it may create a Whop account for your email address or email you itself (see 2.3). The form also uses Stripe, HUMAN Security, hCaptcha, Sardine, Cloudflare and Apple Pay; 2.2 says what each does and links to its privacy policy. All of this only happens if you open the form or sign up on Whop.
• Google LLC (Google Workspace, Gmail) — our address freelime@esmhconsulting.com is an alias of our Google Workspace mailbox, so emails you send us, and emails we send you from an E.S.M.H Consulting address, are handled by Google. Google may process this data on servers in the EU and the US.

We do not sell, rent, or share your data with anyone for marketing purposes. We don't pass your data to anyone else, unless the law requires us to.

5. International transfers

We're based in the United Arab Emirates, and our providers operate globally. Whop and the other services listed in 2.2 process data in the USA and in other countries, and Google may process it in the EU and the US. So your data may be processed outside the country where you live, outside the UAE and outside the European Economic Area and the UK (in particular, in the United States). These countries may not protect personal data to the same standard as the UAE or your own country.

Where this happens, we rely on the European Commission's Standard Contractual Clauses or equivalent safeguards offered by our providers. For Whop and the other services in 2.2, the safeguards are those each provider offers under its own terms and privacy policy, which are linked there. When we view waitlist entries in our Whop dashboard or exchange emails with you, your data also reaches us in the UAE.

6. How long we keep your data

• Waitlist entries — kept until we've decided whether to release Freelime, and then for a reasonable period, for example to tell the waitlist about the outcome. If you withdraw your consent earlier, we remove your entry then.
• Emails to us — kept as long as we need them to answer you and deal with your request.
• Server logs — kept by our host on a rolling short retention window (typically 14–30 days).
• Cookies and local storage from the form — as listed in 2.5, or until you delete them.

Whop keeps data it processes for its own purposes as described in its privacy policy. You can ask us to delete your data sooner — see section 7.

7. Your rights

Wherever you live, we will honor the following rights to the extent applicable to you under your local law (these are the rights granted by the EU/UK GDPR; they are also broadly consistent with the UAE Personal Data Protection Law and similar regimes):

• Access — request a copy of the data we hold about you, and information about how we process it.
• Rectification — ask us to correct inaccurate or incomplete data.
• Erasure (“right to be forgotten”) — ask us to delete your data, for example your waitlist entry.
• Restriction — ask us to pause processing while a question is resolved.
• Portability — receive the data you gave us in a structured, machine-readable format, or have it sent to another controller where that's technically possible.
• Objection — object to processing based on our legitimate interests.
• Automated decisions — object to decisions based solely on automated processing that have legal or similarly significant effects on you.
• Withdraw consent — where we rely on consent (loading the waitlist form, and your waitlist entry), withdraw it at any time, with effect for the future.
• Complain to a supervisory authority — for example, the data protection regulator where you live or work, or the UAE Data Office.

To exercise any of these rights, email freelime@esmhconsulting.com. If it's about your waitlist entry, write from the email address you signed up with; we may ask you to confirm that the address is yours before we act. We aim to respond within 30 days. For data you entered in the Whop form, you can also contact Whop directly, as described in its privacy policy.

How to withdraw your consent:

• Waitlist: email us and we'll remove your entry. If joining created a Whop account, you can also manage or delete it in your Whop account settings.
• Loading the form: leave or reload the page to stop Whop's script, and delete the cookies and stored data for this website (and, if you like, for the services listed in 2.2) in your browser's settings. The form doesn't load again unless you click the button again.

Withdrawing your consent doesn't affect what we did with your data before.

8. Security

We use industry-standard precautions to protect your data: HTTPS everywhere, the minimum data set possible, access to our Whop dashboard and our email restricted to Max Roeck on a need-to-know basis, and reputable providers. This website has no database, no sign-up form of its own, and no analytics or cookies of its own (Whop's form sets some once you open it; see 2.5), and waitlist entries are stored by Whop, not on this website. Whop, Google and the other services protect the data they process as described in their own privacy policies. No system is perfectly secure, so we cannot guarantee absolute security, but we do our best.

9. Children

This website and the waitlist are not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have, please contact us and we will delete it.

10. The Freelime app

This notice is about the website and the waitlist. The Freelime app isn't on sale yet. As built today, it keeps its data in a database on your Mac, has no account and no Freelime server, and makes no network connections of its own: no analytics, no tracking, no update checks. Its automatic backups go to a folder you control, by default in your own iCloud Drive, which Apple stores in iCloud.

Planned: a license check in a paid version. If Freelime is released, it is planned as a subscription sold through Whop, and the paid app would check online that your subscription is active. None of this is built yet, and none of it is in the app as it is today. As planned:

• What is sent — about once a day, over HTTPS: your license key, a random device ID that Freelime creates on first launch (not a hardware serial number) and the app version. Our server and Whop also see your IP address as part of the connection.
• To whom — to our own server at freelime.app, which asks Whop whether the subscription is active. Whop acts under its own privacy policy (opens in a new tab). Our server answers with a signed reply that stays valid for about 14 days, so Freelime keeps working offline in between.
• Why, and on what legal basis — only to check that your subscription is active and stays within the planned limit of 2–3 Macs per subscription. For subscribers, the legal basis is Article 6(1)(b) GDPR (performance of the contract with you).
• What is not sent — no time-tracking data, notes, names or amounts.

Before the paid version is released, we'll update this notice with the details, such as where the server is hosted, who else processes license data and how long it's kept.

11. Links to other websites

Links to whop.com and other websites open those websites, where their own privacy policies apply. We have no influence on how other websites handle your data.

12. Changes to this notice

We'll update this notice when the website or the waitlist changes — for example, if we add a new service or Whop changes how its form works. The “Last updated” date at the top will reflect the most recent change. Material changes that affect your rights will be flagged clearly on this page.

13. Contact

Questions about your privacy or this notice? Email freelime@esmhconsulting.com.