Freq Privacy Policy

Welcome to Freq (the "App"). The App is provided or controlled by Freq Technology LTD. ("we" or "us"). We are controller of your personal data in the sense of Art. 4 (7) of the General Data Protection Regulation ("GDPR") and other data protection or data privacy laws in the Member State of the European Union and other Guidelines with a data protection nature regarding the Platform and as such, we are committed to protecting and respecting your privacy.

Our contact details are: Freq Technology LTD. 7 Whittle Gardens, London, SE26 4LN, UK.

The Data protection officer of Freq Technology LTD. may be contacted under alex@freq.ee.

To provide our services to you, we offer you a website and a free app ("App") that you can download onto your mobile phone. This policy sets out the basis on which any Personal Data from you will be processed, collected, used, and disclosed by us when you access or use our website, applications, products and content (collectively, the "Services").

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

The Personal Data We Process Within Our Service

We collect and process Personal Data either directly from you (e.g. when you provide certain information to us) or indirectly (e.g. through our Platform's technology).

"Personal Data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Information you give us as a user.

If you register an account with us to use the App, you must provide us with certain Personal Data, including your name, unique account name and, if provided, your e-mail address, telephone number and your photograph as well as your language selection. You may also be able to register using your user credentials to certain social media sites, such as Twitter, Facebook, Instagram or Google. This information also allows us or other users to find you on the App.

Information we collect about you when you use the Services. When you use our Services we automatically collect your IP address (not using GPS data), device information, or other unique device identifiers, Cookies (as defined below), browsing records, mobile carrier, time zone and locale setting, mobile or device model, operating system and platform as well as information regarding your use of the Services, e.g. the comments you make on our App or any other user-generated content and video content that you broadcast on our App.

Furthermore, we collect behavioural information, for example, collecting engagement scores (likes, comments, repeated views) and relate users based on your behaviour, alongside marketing information such as opt-ins and communication preferences. We also collect information about linking your contact or subscriber information with your activity across our Services or by linking your activity on our App across all your devices using your email or social media log-in details.

When you use our App we may collect your account name, e-mail address, telephone number, photographs and any Personal Data in connection with videos of that you upload as well as the mobile phone model and the mobile phone operating system version. We further process information about your location based on IP address once to select the videos that we display according to your place of residence.

Information you choose to share from your social networks. If you choose to link the App to your social network or public forum account (such as Facebook), you may provide us or allow your social network to provide us with information from your social network or public forum accounts. This data may include your use of the App on such public forums and/or social networks (e.g. your public profile information, e-mail address and friends list). For further information as to how and for what purpose the social network provider processes your Personal Data, please see their privacy policies.

Find other users and invite your friends. You may find other users of the App either through (i) your phone contacts or (ii) Facebook contacts. If you chose to find other users through (i) your phone contacts, we will access your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the App by matching them with existing users of the App. If you want to find other users through (ii) your Facebook contacts, we may process your public Facebook information as well as names and profiles of your Facebook contacts in accordance with the privacy provisions of Facebook. You may also invite selected recipients to join our App by sending them an e-mail with your profile, including you profile information.

Messages. We collect and process information you provide, including any Personal Data, in the context of composing, sending, or receiving messages (that means the content as well as the information when the message has been sent, received and/or read and the participants of the communication) through our Service's messaging functionality. Please be aware that messages sent to other Users of our Service will be accessible by those other Users and that we are not responsible for the manner in which those Users use or disclose messages.

Metadata. When you upload a video to the App (User Content) you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that may not always be evident to the viewer. In connection with your video the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes Personal Data such as your account name that enables other user to trace back the video to your user account. Metadata may further consist of additional Personal Information that you chose to provide with the video, e.g. any hashtag to mark keywords to the video or comments.

Information from third parties. We may receive information if you use any of the other websites we operate or other Services we provide. We may also receive information from third party SDKs, and from other sources, including business directories and other commercially or publicly available sources. Please find a list of the information that we receive from third parties, including the respective third parties.

 

Cookies. We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) ("Cookies") to enhance your experience using the Services. Cookies are used to indirectly collect information, including Personal Data, from you. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

Although most Web browsers automatically accept Cookies, the decision of whether to accept or not is yours. You have the choice to accept or decline Cookies by way of consent (we may drop Strictly necessary Cookies even without your consent). If you do not accept Cookies, we will not be able to tailor the ads shown to you and you will receive only ads without customized content. Cookies placed by us will expire when you terminate the website session or after 90 days.

There are different Types of Cookies:

Analytics information. On our website, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the users on the Services. These tools, for example, collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a user of the Platform to provide services in accordance with these activities.

Our third party analytics tool is Google Analytics provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics uses Cookies, small text files containing a string of alphanumeric characters and being stored on your computer. Google will use this information including your truncated IP address to assemble statistics on the use of our Service on to provide other related services as described above. For further information on how Google Analytics collects and processes information about you and information on how to opt out from Google's collection of information from you, please click here. You may also find further information in the Google Analytics Terms of Service & Privacy.

We further use "Facebook Pixel" of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"). This tool is solely used for retargeting purposes in order to reveal if you have seen our advertisement on Facebook. If you do not want Facebook to collect the described information about you, you can opt-out of Facebook's use of cookies and Facebook Pixel here.

Please note that our websites do not respond to "do-not-track" signals in your web browser. "Do-not-track" signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services.

How We Use Your Personal Data

We will use your Personal Data for the following purposes:

Personal Data that we collect from your visit on our website is processed for system administration (e.g. to improve our Website and services to you), for statistical or security proposes (e.g. to guarantee the website's stability and security) of our website as well as to solicit your feedback. The processing of this Personal Data is necessary for the purposes of our legitimate interests pursuant to Art. 6 (1) lit. f GDPR.

The e-mail address and content of the e-mail, including the names and addresses, if provided, for your use of the Services will be processed by us to verify that we are allowed to provide you with the Services, Art. 6 (1) lit. c GDPR.

When you register as user of our Services, we obtain Personal Data to create your user account, which is necessary to provide you with you the Services according to Art. 6 (1) lit. b of the GDPR. We may further use your Personal Data from your registration in accordance with Art. 6 (1) lit. b GDPR to:

We may use your Personal Data from your registration that identifies you as a user of the Service also to allow other users to identify you via the "Find other friends" function as a user of the Service as well as your phone contacts to find other users and to connect you on the Platform and support the socializing function of the Services in accordance with our legitimate interest to provide users the ability to connect on the Services for a more lively community, Art. 6 (1) lit. f GDPR. Furthermore, in the "Find other friends" function you may send an e-mail to anyone via your e-mail provider and invite him/her to use the App. In order to fulfil our legitimate interest according to Art. 6 (1) lit f GDPR to expand our Services and increase your user friends, we provide you with your profile information to send to anyone you choose.

We collect and process the Personal Data of your User Content in order to provide you the Services and to enable you to participate on the Platform and interact with other users, Art. 6 (1) lit. b GDPR. Without the submission of your Personal Data such as your name, user account name or the Personal Data within your User Content we may not be able to provide you with our service. We further use your Personal Data to make the Personal Data available to other Users in accordance with the privacy settings you chose for the respective Personal Data. Changes to the privacy settings in the App will immediately apply and also affect Information that you have posted in the past.

We may also process your Personal Data of your use of the Service to show you content that is similar to content you liked or interacted with (by comments and/or watching), content from your region as well as by users you follow. This processing of Personal Data of you helps us to improve the content of the Service in accordance with Art. 6 (1) lit. f GDPR.

In particular, we will process your Personal Data to be responsive to you and to ensure the proper functioning of our products and organisation, Art. 6 (1) lit. f GDPR. As it is in our legitimate interests, we may use your Personal Data to:

If you provide your consent, we may promote the Services and use information that you give to us, such as user-generated content and video content that you may choose to broadcast on our App, as part of our advertising and marketing campaigns to promote the Services in accordance with Art. 6 (1) lit. a GDPR.

The processing of your Personal Data in relation to the usage of the messenger function is solely for the purpose to provide this functionality of the Service to you pursuant to Art. 6 (1) lit. b GDPR, in order for you to contact other users of the Service. It will only be processed if you choose to use this function. You may choose to delete any Personal Data in this regard on your discretion via the clear cache function within the App's settings.

How We Share Your Personal Data

We may share your personal data with selected third parties in or outside your country, including:

 

We may further share your information with law enforcement agencies, public or tax authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

We may also disclose your information to third parties:

Where We Store Your Personal Data

The Personal Data that we collect from you may also be transferred to, and stored at, a destination outside of your country and the European Economic Area ("EEA"), specifically, to third party servers in the United States of America and Europe. We transfer your Personal Data to the servers of our host providers such as Google Cloud.

The Security of Your Personal Data

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk. We do have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other Users. We maintain these technical and organizational measures and may amend them from time to time to improve the overall security of our systems. We also ensure that our third party vendors will provide the same level of protection as provided in the terms of this Privacy Policy.

The transfer of your Personal Data to our host providers is conducted under an adequate level of data protection as compared to the GDPR because all providers have certified themselves under the EU-US-Privacy Shield.

We may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

Data Retention

We will retain your information for so long as we are required to retain such information under applicable laws.

After you have terminated your use of our services, we may store your information in an aggregated and anonymised format. Notwithstanding the foregoing, we may also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

Information Relating to Children

The Services are not directed at children under the age of 13. Users under the relevant age of majority are not allowed to use the Services or register an account on the App without the consent of their parent of guardian. If we become aware that Personal Data has been collected from a person under such age in the relevant jurisdiction and parental or guardian consent has not been provided, we will delete this information and terminate the person's account. If you believe that we may have Personal Data about or collected from a child under the specified age in the relevant jurisdiction without the consent of their parent or guardian, please contact us at privacy@freq.ee.

Your Rights

You have the right to access your Personal Data that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Data where it is inaccurate, or has been processed in violation of the applicable data protection regulations, unless we have to keep the Personal Data for legitimate business or legal purposes. Prior to the fulfilment of your request concerning your Personal Data, we may ask you to verify your identity before we can act upon your request.

You may object to the use or processing of your Personal Data or withdraw consent to use your Personal Data at any time.

You have the following rights:

Please send an e-mail to us if you would like to exercise any of your rights (privacy@freq.ee).

Complaints

In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at privacy@freq.ee and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

Changes

We will use commercially reasonable efforts to generally notify all users of any material changes to this Policy, such as through a notice on our Services, however, you should look at this Policy regularly to check for such changes. We will also update the "Last Updated" date at the top of this Policy, which reflects the effective date of such Policy. Your continued access to or use of the Services after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Services.

Contact

Questions, comments and requests regarding this Policy are welcomed and should be addressed to privacy@freq.ee.

List of third parties that freq.ee collects Personal Data of its users

Third party

Personal Data

Facebook

email, friends list, public profile info (based on user setting e.g., age, name, gender)

Google

email, friends list, public profile info (based on user setting e.g., age, name, gender)

Instagram

email, friends list, public profile info (based on user setting e.g., age, name, gender)

Twitter

email, friends list, public profile info (based on user setting e.g., age, name, gender)