Privacy Policy

Last updated: 2020-09-04

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” means our iOS or Android app “Frever” and our domains frever.com and friendfactory.com.  

"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

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“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 which may include:

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

  • Your user-generated content, such as voice recordings, photos, videos, text, messages, names and comments.

  • Your opt-in choices

  • Your correspondence with us

 

We Process this Information in a number of ways, including when you create or change account in our Products, when you create user-generated content in our app Frever or 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 Products. This Information includes:

  • Your activity on the Products, such as characters created, progression, level status, videos created and number of logged-in sessions;

  • Your interactions with our email and notification messaging such as open/read ratio, time of opening;

  • Your location including location information based on your SIM card and/or IP address.

  • 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;

  • 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 Products. 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 EULA. To better understand how these Service Partners’ Process your data please see the Privacy Policy’s for the respective Service Partner below:

  • Unity 3D (Unity Technologies ApS.), a game engine platform that help us build and run our Products. Unity requires access to some technical Information about your device in order for our Products 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. AWS is hosting our databases and servers. AWS will thus Process Personal Data such as emails, voice files, photos, videos, comments etc. that you upload to the Products using your account. This Personal Data is Processed and sent to AWS. Please read more on how AWS Process Data here.   

 

  • Unity Analytics (Unity Technologies ApS.), an analytics service that helps us analyze user behavior in Frever, analyze crashes of Frever in order to improve our Products and personalize your Product 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.

 

  • Google Analytics (Google Inc.), an analytics service that helps us analyze your behavior in our Products in order to improve our Products, 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 in order to improve our Products, personalize your experience with our Products 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 your and others product experience and we use it to perform marketing efforts, to Process your registration, and to communicate with you on these and other topics. We use the Information to:

  • Allow you to create the User Content in accordance with the EULA.

  • 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, 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.

 

Context 1: When you use our Products:

  • 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 Products to you in accordance with the EULA).

 

  • 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).

 

Context 2: When you interact with our Customer Support in relation to our Products:

  • 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 recollection of previous issues related to you when helping you in Customer Support)

 

Context 3: When you receive marketing communication from us (outside of Context 1 and 2):

  • 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).

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 outlined below:

Service Partners 

 

We use Service Partners to help us perform certain services on our behalf or to assist us with the providing you with the Products. We may engage Service Partners to provide data storage, analytics, marketing, communications, advertising, infrastructure and IT services, to provide customer service, to analyze and enhance data (including data about your usage of the  Products), and to Process and administer consumer surveys. When providing such services, these Service Partners may have access to your Personal Data or other Information. We do not allow these Service Partners to use or disclose your Personal Data except in connection with providing their services on our behalf.

Protection of Friend Factory and third-parties 

 

Friend Factory and its Service Partners may use and disclose your Personal Data and other Information where we or they reasonably believe such disclosure or use 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 

If Friend Factory should go through any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer Information to a third party, 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. 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 European Union (Frankfurt). 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 outside of the European Union by us or our agents and contractors. The data protection laws of 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 Products (all anonymized and non-personal Data) is automatically becoming the property of Friend Factory according to the EULA 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 Products and our operations, which may include retaining your Personal Data beyond the end of your use of the Products.

Your Choices

Email 

If you no longer want to receive certain communications from us via email, click the "unsubscribe" link in the email. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your account transactions or updates to this Privacy Policy or EULA.

 

Public and Private Videos

If you do not wish to share any user-generated content you have made, you do not need to. By clicking on “Private” when you publish your content the video will be displayed only for you.

Disclosure

You may also choose to disclose your Personal Data in the following ways:

  • While using our Customer Service on a third-party platform (such as Facebook Messenger);

  • 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. Thus, if you share your Personal Data to these third-party platforms this Personal Data will be governed by their Privacy Policy and not ours.

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 "Settings" page of Frever.

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 how we handle your Personal Data 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.  If you withdraw your consent it will not affect the lawfulness of any Processing that happened prior to your withdrawal, nor will it affect Processing of your Personal Data conducted in reliance on other lawful Processing grounds other than consent, such as any interaction with out Product. 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 to fulfill the purposes described in this Privacy Policy. 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 and to deliver tailored marketing or advertising to you. It is important that you know about 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?

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work better and allow to personalize ads. Only we can access the cookies created by our website. You can control your cookies at the browser level. 

2. Why does Friend Factory use cookies?

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

  • Performance and functionality cookies: These help us to personalize and enhance your experience with our Products. 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 Products 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 Products or complete non-functionality.

  • Advertising cookies: These cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. Many of the advertising cookies associated with our service belong to our Service Partners.

 

3. 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:

4. 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, analyze actions on our site, and understand interactions with our marketing. Because Web beacons often work in conjunction with cookies, declining cookies may impair the effectiveness of Web beacons associated with those cookies.

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