THEMECOMPLETE LTD Privacy Policy
THEMECOMPLETE LTD (“ThemeComplete”, “we”, “us”, or “our”) is committed to protecting your privacy and handling your personal data in a transparent and lawful manner.
This Privacy Policy explains how we collect, use, store, and share your personal information when you use our websites, products, support services, and related platforms.
This Policy applies to all users of our services, including customers who purchase via Envato Market, Freemius, or any other authorized distribution channel, as well as users who access our support services.
1. Data Controllers and Roles
Depending on how you interact with our products and services, different entities may act as data controllers:
- THEMECOMPLETE LTD – Controller for product usage, support services, and direct communications.
- Freemius – Acts as Merchant of Record (MOR) and independent data controller for payment processing, taxation, licensing, and related account management.
- Envato Market – Independent data controller for purchases made through its marketplace.
Each platform processes your data under its own privacy policy and legal obligations. We are not responsible for data handling performed independently by Envato or Freemius.
2. Information We Collect
We collect information in the following ways:
2.1 Information you provide directly
- Name and email address
- Account information (depending on platform used: Freemius, Envato, or support system)
- Support tickets and communications
- Purchase or license-related information (processed via Freemius or Envato)
2.2 Automatically collected information
- IP address and browser information
- Device and operating system data
- Log data (access times, actions performed)
- Basic usage and interaction data where applicable
2.3 Cookies and similar technologies
We use cookies and similar technologies to operate and improve our services, including authentication, security, and performance analytics.
You may disable cookies in your browser, but some functionality may not work properly.
2.4 Google reCAPTCHA
We use Google reCAPTCHA to protect our forms and services from spam and abuse.
reCAPTCHA analyzes hardware and software information, such as device and application data, and it may collect data such as IP address and user behavior patterns.
This service is subject to the
Google Privacy Policy and
Google Terms of Service.
3. How We Use Your Data
- To provide and maintain our products and services
- To deliver customer support
- To manage licenses (via Freemius)
- To process transactions (via Freemius or Envato)
- To improve product functionality and security
- To prevent fraud, abuse, and unauthorized access
4. Freemius Merchant of Record (MOR)
Freemius acts as the Merchant of Record (MOR) for purchases made through its platform. This means Freemius is responsible for:
- Processing payments and issuing receipts/invoices
- Handling applicable taxes (VAT, sales tax, etc.)
- Managing customer purchase records
- Providing license management infrastructure
In this context, Freemius may act as an independent data controller for certain payment and transactional data.
We do not control or store full payment card information.
5. Legal Basis for Processing (GDPR)
We process personal data under the following legal bases:
- Contract: To provide purchased products, licenses, and support
- Legal obligation: For tax, accounting, and compliance requirements
- Legitimate interest: For security, product improvement, and fraud prevention
- Consent: Where explicitly required (e.g., optional communications)
6. Data Sharing and Third Parties
We may share data with the following categories of third parties:
- Freemius – for licensing, payments, and account management (MOR)
- Envato Market – for marketplace purchases and account handling
- Service providers – hosting, support systems, and infrastructure providers
- Google – for reCAPTCHA and optional font delivery
We do not sell personal data to third parties.
7. International Data Transfers
Your data may be processed in countries outside your own, including the European Union and the United States.
Where data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent legal mechanisms.
8. Data Retention
We retain personal data only for as long as necessary to:
- Provide our services
- Maintain license validity
- Fulfill legal and accounting obligations
- Resolve disputes and enforce agreements
Retention periods may vary depending on the type of data and applicable legal requirements.
9. Data Security
We implement appropriate technical and organizational measures to protect personal data, including encrypted communication (SSL/TLS), access controls, and secure infrastructure.
However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
10. Your Rights (GDPR)
You have the right to:
- Access your personal data
- Request correction or deletion
- Restrict or object to processing
- Request data portability
- Withdraw consent at any time (where applicable)
- Lodge a complaint with a supervisory authority
Requests can be submitted via our support system.
11. Support Account System
To provide customer support, users may be required to create an account on our support platform.
This system is separate from Freemius and Envato accounts.
Support accounts are used solely for handling technical assistance and communication.
12. Third-Party Links
Our services may contain links to third-party websites. We are not responsible for the privacy practices of those websites.
13. Children’s Privacy
Our services are not intended for children under 13, and we do not knowingly collect personal data from children.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last Updated” date.
Continued use of our services after changes indicates acceptance of the updated policy.
15. Contact
If you have any questions about this Privacy Policy, you may contact us via our support system.