Copyright © 2018-2019 Friend Factory AB

Last updated: 2019-05-24

This Privacy Policy explains Our practices, regarding the Processing, use, sharing, transfer and disclosure of certain Information, including Personal Data, when a physical person (“You”, “Licensee”) interact with the Products & Services operated by or on behalf of Friend Factory AB (“Friend Factory”, “We”, “Us”, “Our”). 

This Privacy Policy also forms part of the Beta-User License Agreement ("BULA") and the End User License Agreement (“EULA”) that explain Your rights and responsibilities and Ours when using Our Products & Services.  

Friend Factory is highly committed to protecting the privacy of Our users. By accepting Our BULA/EULA You also give Your consent that We protect Your privacy in accordance with this Privacy Policy.  

Definitions

“Products & Services” means Our application "Frever”, Our domain https://friendfactory.com, and Our Customer Service. 

"Personal Data" means any Information relating to a physical person (“You”) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.

“Data” means any Information that is not Personal Data

“Information” means Personal Data and Data

"Processing" means any operation which is performed on Personal Data, such as Processing, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.

Contacting Us

If You have general questions about how We use, Process and Process Your personal data, please contact privacy@friendfactory.com. The data controller of Your Personal Data is Friend Factory AB. 

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard Your Personal Data against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of Processing Your Personal Data.

Children

You must be 13 years of age or older to use Our Products & Services. In general, if You are under the age of 13, it is a good idea to talk to and ask Your parent(s) or guardian(s) for permission before using the Products & Services. If You do not get such permission, You should not use Our Products & Services. Parents should contact us immediately if they have any concerns regarding the Products & Services using the email above. 

Our Processing of Information

Information You provide to us

We Process Information You provide to us through Our Products & Services which includes:

  • Your name, age, email address, address or postal code, payment method(s), and telephone number. 

We Process this Information in a number of ways, including when You create or change creator account in Our Service, when You interact with Our customer support, or participate in surveys, sweepstakes or marketing promotions by Us. 

Information We Process automatically: 

We Process Information automatically when You use Our Product & Services. This Information includes:

  • Your activity on the Product or Service, such as game progression, level status, events created and number of logged-in sessions;
    • Your interactions with Our email, push and notification messaging such as open/read ratio, time of opening;

    • details of Your interactions with Customer Service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if You call us, Your phone number;

    • advertising identifiers, such as those on mobile devices (IDFA and GAID), tablets, and streaming media devices that include such identifiers (see the "Cookies and Internet Advertising" section below for more Information);

    • uniquely assigned and randomized device and software identifiers (generated through MAC, or IMEI-numbers), connection Information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us Your general location), browser and standard Web server log Information;

    • Information Processed via the use of cookies, Web beacons and other technologies, including ad data (such as Information on the availability and delivery of ads, the site URL, as well as the date and time). (See Our "Cookies and Advertising" section for more details.)

Information We Process through third-parties: 

The Information You either provide to us or We Process automatically may be Processed through other companies, agents or contractors ("Service Partners"). We protect this Information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by Our Service Partners. These Service Partners may vary over time and the manner in which You contact Us or interact with our Product & Services. However, at the time of latest update of this Privacy Policy the Service Partners listed below will automatically Process Information when you use enter into the BULA and/or EULA. To better understand how these Service Partners Process Your data please see the Privacy Policy’s for the respective Serive Partner below:

  • Unity 3D (Unity Technologies ApS.), a game engine platform that help us build and run our Products & Services. Unity requires access to some technical Information about the Your device in order for our Product & Services to function. For example, Unity may Process Information such as, device manufacturer, hardware components, device and network identifiers, user language etc. The Processed Information is sent to Unity and aggregated or anonymized in such form that the aggregate-level data which is being stored contains no Personal Data. Please read more on how Unity Process Data here.

 

  • Amazon Web Services (“AWS”) (Amazon Inc.), is a mobile development platform that helps us build and run our Products & Services. AWS requires access to Personal Information about Your device and Your recordings in order for our Products & Services to function. For example, AWS may Process Information such as: sound recordings, IP-number, and unique device information automatically. Please read more on how AWS Processes Personal Data here.    

  • Unity Analytics (Unity Technologies ApS.), an analytics service that helps us analyze Your behavior in Frever, analyze crashes of Frever in order to improve our Products & Services and personalize Your game-experience. The Information Processed in order to analyze Your behavior may constitute Personal Data (such as IP-addresses, MAC-addresses and device IDs). Please read more on how Unity Process Data here.

 

  • OneSignal (One Signal Inc.), a notification service that helps us send notifications to Our Frever users, create unique and anonymous IDs for each user and analyze the user’s interaction of the same. The Information Processed in order to send notifications and analyze them is anonymized, meaning that it does not contain any Personal Data. Please read more on how One Signal Process Data here.  

 

  • Google Analytics (Google Inc.), an analytics service that helps us analyze Your behavior in our Products & Services in order to improve our Products & Services, personalize Your experience with our Products and Services as well as to personalize interest-based ads. The Information Processed may contain Personal Data such as IP-addresses and device IDs, such as IDFA or GAID. Please read more on how Google Process Information here.  

 

  • Facebook Business Tools (Facebook Inc.), an analytics service that helps us analyze Your behavior in our Products & Services in order to improve our Products & Services, personalize Your experience with our Products and Services as well as to personalize interest-based ads. The Information Processed may contain Personal Data such as IP-addresses and device IDs. Please read more on how Facebook Process Information here.    

 

Our use of Information

We use Information to provide, analyze, administer, enhance and personalize Our Products & Services and We use it to perform marketing efforts, to Process Your registration, Your orders and Your payments, and to communicate with You on these and other topics. For example, We use Information to:

  • analyze and understand Our users, improve Our service (including Our user interface experiences) and optimize content selection, recommendation algorithms and delivery;

  • determine Your general geographic location, in order to provide localized content and support;

  • prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing Our terms (such as determining free trial eligibility);

  • communicate with You concerning Our service (for example by email, push notifications text messaging, and online messaging channels), Please see the "Your Choices" section of this Privacy Statement to learn how to set or change Your communications preferences.

Our legal basis for Processing and using the Personal Data described in this Privacy Policy will vary depending on the context in which the Personal Data was provided. But four grounds are typically used:

  • We will Process Personal Data where We need the Personal Data to perform a contract with You (for example and most importantly, to provide Our Product & Services in a well-functioning fashion to You). 

 

  • We will Process Personal Data where it is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms (for example, Our legitimate interest in ensuring Our Products & Services Customer Service work as intended and with recollection of previous issues related to You)

 

  • We will Process Personal Data from You when We have Your consent to do so (for example, for You to participate in certain consumer insights activities like specific surveys and focus groups or agree that We send You a marketing email or newsletter). 

 

  • We may also have a legal obligation to Process Personal Data from You or may otherwise need the Personal Data to protect Your vital interests or those of another person (for example, to prevent fraud or confirm Your identity). 

 

For questions about Our use of Your Personal Data (including legal bases and transfer mechanisms We rely on), cookies or similar technologies, please contact Our Data Protection Officer by email at privacy@friendfactory.com 

Our disclosure, transfer, retention and sharing of Information

We disclose Your Information for certain purposes and to third parties, as described below:

Service Partners 

We use Service Partners to perform services on Our behalf or to assist us with the provision of services to You. For example, We engage Service Partners to provide analytics, marketing, advertising, communications, infrastructure and IT services, to personalize and optimize Our service, to Process credit card transactions or other payment methods, to provide customer service, to analyze and enhance data (including data about users' interactions with Our service), and to Process and administer consumer surveys. In the course of providing such services, these Service Partners may have access to Your Personal Data or other Information. We do not authorize them to use or disclose Your Personal Data except in connection with providing their services.

Protection of Friend Factory and third-parties 

Friend Factory and its Service Partners may disclose and otherwise use Your personal and other Information where We or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal Process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Friend Factory, its users or the public, as required or permitted by law.

Business transfers 

In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, We will transfer Information, including Personal Data, provided that the receiving party agrees to respect Your Personal Data in a manner that is consistent with this Privacy Policy.

Data

We, may also share aggregated, automatically-Processed, or otherwise non-personal data (“Data”) with third parties for various purposes, including (i) reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding Our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Products & Services. We do not share personal data about You in this case.

Geographical Storage of Data 

Friend Factory through its Service Partners, Process Information on secure servers located in the United States of America. Such storage is necessary in order to Process the Information.

Friend Factory operates globally and We may transfer Personal Data that We Process from You to Our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside of Your country or regional area, and may be Processed by staff operating outside Your country or regional area. In particular, Information provided to us or Processed by us likely will be transferred to and Processed in the United States by us or Our agents and contractors. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in Your country of residence. Wherever We transfer Your Personal Data, We will take reasonable steps to ensure that Your privacy rights continue to be protected.

Retention

All Data that We Process from Your use of our Product & Services (all anonymized and non-personal Data) is automatically becoming the property of Friend Factory according to the BULA and/or EULA Agreement You have agreed to, and thus stored at Our sole discretion. 

We may retain your Personal Data that has been provided to Us or automatically collected by Us under the legal basis listed above for as long as is necessary and relevant to Your use of our Product & Services and Our operations, which may include retaining your Personal Data beyond the end of Your use of the Product & Services.

Your Choices

Email 

If You no longer want to receive certain communications from us via email, simply access the "Settings" option in the "Account" section of Our Website and uncheck those items to unsubscribe. Alternatively, click the "unsubscribe" link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that You cannot unsubscribe from service-related correspondence from us, such as messages relating to Your account transactions.

Push Notifications 

You can choose to receive mobile push notifications from Friend Factory. If You subsequently decide You no longer wish to receive these notifications, You can use Your mobile device's settings functionality to turn them off.

Interest-Based Ads 

Interest-based ads are online ads that are tailored to Your likely interests based on Your use of various apps and Websites across the Internet. If You are using a browser, then cookies and Web beacons can be used to Process Information to help determine Your likely interests. If You are using a mobile device, tablet, or streaming media device that includes an advertising identifier, then that identifier can be used to help determine Your likely interests. For Your choices about interest-based ads from Friend Factory, please see the "Cookies and Internet Advertising" section (below).

Disclosure

You may also choose to disclose Your Information in the following ways:

  • while using Our Customer Service in an open forum setting, You will have opportunities to post reviews or other Information publicly, and third parties could use the Information You disclose;

  • social plugins and similar technologies allow You to share Information with others.

Social plugins and social applications are operated by the social networks themselves, and are subject to their terms of use and privacy policies.

Your Rights 

You can request access to Your Personal Data, or correct or update out-of-date or inaccurate Personal Data We hold about You. You can most easily do this by visiting the "Account" portion of Our Website, where You have the ability to access and update a broad range of Information about Your account, including Your contact Information, Your Friend Factory payment Information, and various related Information about Your account. 

You may also request deletion, withdrawal or portability of Your Personal Data that We hold about You. To make requests, or if You have any other question regarding Our privacy practices, please contact Our Data Protection Officer privacy@friendfactory.com. We respond to all requests We receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. 

You can object to Processing of Your Personal Data, ask us to restrict Processing of Your Personal Data or request portability of Your Personal Data; if We have Processed and Process Your Personal Data with Your consent, then You can withdraw Your consent at any time.  Withdrawing Your consent will not affect the lawfulness of any Processing We conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful Processing grounds other than consent. You have the right to complain to a data protection authority about Our Processing and use of Your Personal Data. 

We may retain Information as required or permitted by applicable laws and regulations, including to honor Your choices, for Our billing or records purposes and to fulfill the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify Personal Data in a secure manner when it is no longer required.

Cookies and Advertising

We and Our Service Partners use cookies and other technologies (such as Web beacons), as well as advertising identifiers, for various reasons. For example, We use these technologies to make it easy to access Our services by remembering You when You return, to provide and analyze Our services. We also use cookies, as well as advertising identifiers, to learn more about Our users and their likely interests, and to deliver and tailor marketing or advertising. We want You to be informed about Our use of these technologies, so this section explains the types of technologies We use, what they do and Your choices regarding their use.

1. What are cookies?

Cookies are small data files that are commonly stored on Your device when You browse and use Websites and online services. They are widely used to make Websites work, or to work more efficiently, as well as to provide reporting Information and assist with service or advertising personalization.

Cookies are not the only types of technology that enable this functionality; We also use other, similar types of technologies. See below for more Information and examples.

2. What are advertising identifiers?

Advertising identifiers are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" (or IDFA) on Apple iOS devices and the "Google Advertising ID" on Android devices). Like cookies, advertising identifiers are used to make online advertising more relevant.

3. Why does Friend Factory use cookies and advertising identifiers

  • Essential cookies: These cookies are strictly necessary to provide Websites included in Our Products & Services. For example, We and Our Service Partners may use these cookies to authenticate and identify Our members when they use Our Products & Services so We can provide Our service to them. They also help us to enforce Our BULA, prevent fraud and maintain the security of Our service.

  • Performance and functionality cookies: These cookies are not essential, but help us to personalize and enhance Your experience with Our Products & Services. For example, they help us to remember Your preferences and prevent You from needing to re-enter Information You previously provided (for example, during member sign up). We also use these cookies to Process Information (such as popular pages, conversion rates, viewing patterns, click-through and other Information) about Our visitors' use of the Friend Factory service so that We can enhance and personalize Our Website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of Our Product & Service or complete non-functionality.

  • Advertising cookies and advertising identifiers: These cookies and advertising identifiers use Information about Your use of this and other Websites and apps, Your response to ads and emails, and to deliver ads that are more relevant to You. These types of ads are called "interest-based advertising." Many of the advertising cookies associated with Our service belong to Our Service Partners.

4. How can I remove cookies and advertising identifiers?

To opt out of interest-based ads from Friend Factory in connection with an advertising identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on Your device (usually found under "privacy" or "ads" in Your device's settings). You may still see ads by us on Your device, but they will not be tailored to Your likely interests.

Friend Factory supports the following self-regulatory programs, which provide additional privacy choices for interest-based advertising:

5. How Does Friend Factory use Web Beacons and other Technologies?

We and Our Service Partners may use Web beacons (also known as pixel tags). We use these to understand and enhance the use of Our service, improve site performance, monitor visitor traffic and actions on Our site, and understand interactions with Our marketing (including email and online ads on third party sites). Because Web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness of Web beacons associated with those cookies.