Privacy policy.

This privacy policy describes how Fresnaye & Company (“we,” “our”) and our subsidiary brands and applications (Fresnaye Prism, Travel by Fresnaye, Fresnaye Reserve, Fresnaye Connect, Fresnaye Ledger, Fresnaye Card, Andaman Atlas, Restaurant Franchise Management, LookinGlass, Fresnaye Pulsepoints) collect, use, share, and protect personal information.

“Fresnaye & Company” means Fresnaye & Company LLC, 2001 L Street NW, Suite 500, Washington, DC 20036, United States; Fresnaye & Company Ltd, 128 City Road, London EC1V 2NX, United Kingdom (Company No. 17056956), which is the controller for personal information processed in connection with our European operations; and Fresnaye & Company Limited, Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong (Business Registration No. 81022192), which is the controller for personal information processed in connection with our Asia-Pacific operations.

Fresnaye Pulsepoints is a lobby display for Apple TV. It has no accounts and no sign-in, and collects no personal information. It sends only a randomly generated identifier for the screen itself, so the right content can be assigned to the right display; that identifier is not linked to any person or device identity. The sections below describe our other applications.

Fresnaye Prism is the app for clients and associates of Fresnaye & Company, on iOS, Android and the web at fresnaye.com/portal. It brings Travel by Fresnaye, LookinGlass, Fresnaye Connect and Fresnaye Card into one sign-in, so the information described for those applications below is the information Prism shows you, and you see only the services you use. Accounts are opened by Fresnaye: a travel advisor opens a client’s account after an introduction (travelbyfresnaye.com/app.html), a LookinGlass account is opened when a company’s access request is approved, and the firm opens its associates’ accounts. The app has no self-service registration and no in-app purchases. On a phone, Prism asks for device permissions only when you use the related feature: the camera and photo library when you choose to upload a profile photo, a receipt or a trip document; the microphone only while you dictate a message to LookinGlass, where the audio is transcribed and not retained; notifications for workplace, travel and card alerts, which you can switch off by category in your profile or in your device settings; and Face ID or Touch ID if you turn on the app lock, which is handled entirely by your device — the firm never receives biometric data. Flight Live Activities show the status of your upcoming flights on the Lock Screen and are delivered through Apple’s push service. Prism uses no third-party analytics or advertising identifiers and does not track you across other apps or websites.

1. Information we collect

We collect information you provide directly to us, including:

• Account information. Name, email, organization, role, and credentials when you create or sign in to one of our applications.
• Contact submissions. Name, email, organization, and message content when you reach out through this website or a partner inquiry form.
• Usage data. Pages visited, features used, session duration, device type, operating system, browser type, IP address (anonymized for analytics).
• Workplace data (FresnayeConnect only). Office check-ins, bookings, events, peer recognition, and messaging within our internal workplace platform.
• Travel data (Travel by Fresnaye only). Trip itineraries, booking confirmations, traveler preferences.
• Financial data (Fresnaye Ledger only). Budgets, accounts, and transactions you add to our personal-finance application.
• Card data (Fresnaye Card only). Transactions, statements, receipts and notes for corporate cards issued to you through the firm’s programme.
• Assistant data (LookinGlass only). The messages you send to the assistant and the files you attach, which are processed by the AI providers named in section 3 to produce a reply.

2. How we use information

• To operate, maintain, and improve our applications and services
• To authenticate users and provide single sign-on across our applications
• To respond to inquiries and provide partner-level support
• To send transactional emails (password resets, booking confirmations, invitations) via Microsoft Graph
• To prevent fraud, abuse, and security incidents
• To comply with applicable legal obligations

We do not sell personal information. We do not use personal information for third-party advertising.

3. Third-party services

We use the following third-party services to operate our applications:

• Microsoft 365 / Graph. Email delivery, calendar integration, contact form processing.
• Matomo (self-hosted). Privacy-focused website analytics running on our own servers — cookieless, with IP addresses anonymized. No analytics data leaves our infrastructure.
• Zitadel. Single sign-on / identity management for associate authentication.
• Expo & Apple/Google Push Services. Mobile push notifications for our applications.
• Anthropic Claude / OpenAI. AI assistance within Concierge features and LookinGlass.
• Google Gemini. One of the AI models in LookinGlass. It receives your messages and attached files when it is one of the models answering.
• American Express. Card issuer. Transaction data is imported into Fresnaye Card for reconciliation; Fresnaye Card does not process payments.

4. Data retention

We retain personal information for as long as your account is active, or as needed to provide our services. Contact form submissions are retained for up to 24 months for follow-up. Anonymized usage analytics are retained for up to 36 months. You may request deletion of your data at any time.

5. Your rights

Depending on your location, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate information
• Request deletion of your information
• Object to or restrict certain processing
• Receive a copy of your data in a portable format
• Withdraw consent (where processing is based on consent)

To exercise any of these rights, contact us at privacy@fresnaye.com.

Clients and associates can ask for their Fresnaye Prism account to be closed and their personal information deleted by writing to the same address; records the firm must keep by law or policy are retained as described in section 4.

6. Children

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children.

7. International users

Our servers are located in the United States. Where we transfer personal information from the United Kingdom or the European Economic Area, transfers between Fresnaye & Company entities rely on the EU Standard Contractual Clauses with the UK International Data Transfer Addendum, and transfers to service providers such as Microsoft rely on the safeguards in their data processing agreements.

8. Changes to this policy

We may update this policy from time to time. We will notify users of material changes via email or in-app notification. Continued use of our services after a policy update constitutes acceptance.

9. Contact

For privacy questions, requests, or complaints, contact us at:

Fresnaye & Company
Attn: Privacy Officer
2001 L Street NW, Suite 500
Washington, DC 20036
United States
privacy@fresnaye.com