Privacy Policy

Last updated: December 22, 2023

Frever AB (“Frever”, “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy (“Policy“) explains our Information Processing when a customer (“you”, “your”) visits our websites, mobile app, or otherwise interacts with us, online or offline (collectively, uses our “Services”). “Information” means Personal Data and Data.  “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. “Processing”, “Process”, “Use” or “Usage” 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.

By using our Services, you agree that your Personal Data will be handled as described in this Policy. Your use of our Services and any dispute over privacy is subject to this Policy and our End User License Agreement (“EULA”), including their applicable terms governing limitations on damages and the resolution of disputes.

Depending on how you interact or engage with us, we may provide you with other privacy notices, which contain additional details about our information practices. For example, this Policy does not apply to job applicants and candidates who apply for employment with us, or to employees in the context of the employment relationship.

Table of Contents

  1. Personal Data We Collect
  2. How We May Use Personal Data
  3. Our legal bases for Processing Personal Data
  4. How We May Disclose Personal Data
  5. Retention
  6. Cookies and Other Tracking Mechanisms
  7. Your Privacy Choices
  8. Your rights (EEA only)
  9. External Links and Features
  10. Security
  11. Children’s Information
  12. Changes to this Policy
  13. Contact Us
  14. Service Providers

1. Personal Data We Collect

As further described below, we may collect Personal Data directly from you, automatically through your use of our Services, and from other, third-party sources. To the extent permitted by applicable law, we may combine the Personal Data we collect from publicly available or third-party sources.

Personal Data We Collect Directly From You. While the type of information we collect from you depends on how you use our Services and our interactions with you, in general, we may collect the following Personal Data directly from you:

  • Contact Information and Other Identifiers: If you create an account with us, use our Services, or otherwise communicate with us, we may collect your account name, nickname, email address or Apple ID, IP address, telephone number, contacts and other similar identifiers.
  • Customer Support Data: If you contact our customer service team we may collect details about your interactions with customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, phone number, or any other Personal Data you choose to provide. This includes contacts to our social media account on different platforms, such as Youtube, Facebook, Instagram, TikTok, Linkedin and Discord.
  • User-Generated Content: If you use our Services, create an avatar, and choose to provide the following, we may collect your voice recordings, de-identified face animation recordings, audio files, photos, videos, text and comments.
  • Characteristics of Protected Classifications: If you create an account with us, we may collect your date of birth.
  • Commercial Information: If you use our Services, we may collect records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Inferences: We may also draw inferences from the information described in this section, including inferences reflecting your preferences, characteristics, behavior, and abilities.

Information We Collect Automatically. We may automatically collect Personal Data related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. The Personal Data we may collect automatically includes:

  • Device and Browsing Data: When you use our Services, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information activity.
  • Activities and Usage Data: We may also collect activity information related to your use of the Services, such as information about the links clicked, features used, items viewed, time spent within the Services, your interactions within the Services, and other activity and usage information.
  • Location Information: We may also collect or derive location information about you, such as through your IP address.
  • Ad data: GAID, IDFA, IP-address 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)

For more information about our use of cookies and other similar technologies, please see the “Cookies and Similar Tracking Mechanisms” section below.

Personal Data We Collect from Other Sources. We may also collect or obtain Personal Data about you through our business partners and from other third-party sources, such as public databases, data analytics providers, Internet service providers, operating systems and platforms, and vendors and service providers who provide services on our behalf.

2. How We May Use Personal Data

Generally, we may use the Personal Data we collect for the following purposes:

  • Operate Our Business. We use the Personal Data we collect to run our day-to-day operations.
  • Provide You Services. We use the Personal Data we collect to provide you with our Services.
  • Communicate With You. We use the Personal Data we collect to communicate with you about your use of our Services, to respond to your inquiries, to provide you with the information you request, and for other customer service purposes.
  • Evaluate and Improve Our Services. We use the Personal Data we collect to evaluate, analyze, improve, and develop our Services. We also use this information to tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using our Services.
  • Marketing and Advertising. We use the Personal Data we collect for marketing and promotional purposes, including to send you promotional communications about our Services that we believe may interest you. We may send communications via e-mail, text message, or push notifications on a mobile device.
  • Inferences. We use the Personal Data we collect to better understand how you access and use our Services both on an aggregated and individualized basis. We also use Personal Data to understand our users, optimize content selection, recommendation algorithms, and delivery.
  • Fraud and Security Purposes. We use the Personal Data we collect to mitigate fraud and protect Frever and others. We also use this information to prevent and detect fraudulent, malicious, and deceptive infringements of our policies and contracts and other potential misuse of or illegal activity relating to our Services.
  • Legal Requirements. We use the Personal Data we collect to investigate, enforce, and apply this Policy and related policies, and to otherwise protect our own rights and interests, such as to resolve any disputes or to respond to requests from law enforcement, court orders, regulators, or other legal processes.
  • Other Operational and Business Purposes. We may use your Personal Data for other operational purposes such as to comply with contracts related to the Services that we provide to you. 

3. Our legal bases for Processing Personal Data

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 Services:

  • We will Process Personal Data insofar as Contact Information and Other Identifiers, Location information, Activities and Usage Data, Characteristics of Protected Classifications, Commercial Information, and User-Generated Content where we need the Personal Data to perform a contract with you (for example and most importantly, to provide our Services to you in accordance with the EULA).
  • We may also have a legal obligation to Process Personal Data insofar as Contact Information and Other Identifiers, User-Generated Content, or any other Personal Data, such as to maintain records relating to tax or to respond to a valid legal request for certain data from official authorities.
  • We will Process Personal Data insofar as Device and Browsing Data and Inferences, where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms to detect, prevent, or otherwise address fraud, abuse, security, or technical issues with our Services (for example to understand crash reports or provide recommendations).

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

  • We will Process Personal Data insofar as Customer Support 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, helping you get access to our Services or other matters related to you when helping you in Customer support)

Context 3: When you receive marketing communication from us:

  • We will Process Personal Data insofar as Ad data from you when we have your consent to do so (for example, when you click allow all cookies on our website, 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).
  • If you use an Android device and consent to this Privacy Policy, you explicitly consent to us collecting your Android advertising ID for improving our marketing campaigns outside of Frever and that you are over the age where you are allowed to consent to this Privacy Policy in your state, province, or country.

4. How We May Disclose Personal Data

In accordance with applicable law, we may disclose your Personal Data to our business partners, service providers, marketing and advertising partners, and others.

  • Service Partners. We may disclose the Personal Data we collect with service providers who perform functions on our behalf, such as website hosting and analytics, data hosting, email or other communication services, development and research, and customer support (“Service Partners”). 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. (See section “Service Partners” below to see what Information each Service Partner Process)
  • Marketing and Advertising Partners. We may also disclose your Ad-data, with our marketing and advertising partners to send you content about our Services and to evaluate the performance of our campaigns.
  • Business Transfers. We may disclose the Personal Data we collect from you as part of commercial transactions (e.g., mergers, acquisitions, bankruptcy, or other similar business transactions) and in contemplation of such transactions (e.g., due diligence).
  • Legal Purposes. We may disclose the Personal Data we collect from you to third parties, as permitted by law or subpoena, or if we reasonably believe such action is necessary to comply with the law and the reasonable requests of regulators, law enforcement, other public authorities, or for other similar purposes.
  • Security and Protection of Rights. We may disclose the Personal Data we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy or related policies, or as evidence in litigation in which we are involved. We may also disclose Personal Data to protect our rights and the rights of others.
  • Aggregate and De-Identified Information. We may disclose aggregate or de-identified Personal Data about users with third parties for marketing, advertising, research or other purposes. Where Frever has committed to maintaining and using Personal Data in a deidentified form, Frever agrees not to reidentify deidentified data except as permitted by applicable law.
  • Other Disclosures. We may disclose your Personal Data for other purposes, which we will notify you of or obtain your consent, if necessary.
  • Geographical processing of data. Frever through its Service Partners, Process Information on secure servers located in the European Union and United States. Such storage is necessary in order to Process the Information and any transfer of Personal Data outside of the European Union will comply with the Regulation (EU) 2016/679 (GDPR). We will transfer your information to affiliated entities or third parties to jurisdictions outside the European Economic Area (the “EEA”). If you are located in the EEA, please note that these countries outside of the EEA will not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including adequacy decisions, as applicable, and the use of EU standard contractual clauses) to allow the transfer of your information across borders outside of the EEA.

5. Retention

All Data that we Process from your use of our Services (all anonymized and non-personal Data) is automatically becoming the property of Frever 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 Services and our operations, which may include retaining your Personal Data up to 30 days after you delete your account.

By going into your profile, click on settings, click “Manage account” and then click “Delete account” in the Frever app all Personal Data that have been collected will be deleted after 30 days following deletion of account. If you wish to exercise your right to deletion earlier, please see Your Rights section below on how to contact us.

If you withdraw any consent you have given us, e.g., for our Processing of Personal Data for advertising purposes, we will no longer retain your Personal Data for that purpose. Please note that we may still retain the same Personal Data for another purpose, as defined in this Privacy Policy. It may take a few days for us to update our records before any opt out based on your consent is effective.

6. Cookies and Other Tracking Mechanisms

We and our service providers use cookies, pixels, tags, and other similar tracking mechanisms to automatically collect Personal Data about browsing activity, type of device, and similar information within our Services and to target content across our Services. We use this information to, for example, analyze and understand how users access, use, and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services.

Cookies. Cookies are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, support the security and performance of the Services, or allow us to track activity and usage data within our Services.

Clear GIFs, Pixel Tags, and Other Technologies. In addition to cookies, we may also use pixel tags (sometimes called web beacons or “clear GIFs”) to collect Personal Data about you and your use of our Services. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these and other technologies in connection with our Services to, among other things, track the activities of users, help us manage content, and compile usage statistics. We may also use these in HTML e-mails we send to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us evaluate usage of our Services, improve our Services, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

7. Your Privacy Choices

We provide several ways for you to manage your Personal Data.

  • Cookie Settings. If you wish to prevent cookies from tracking your activity on our Services or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Services who disable cookies will be able to browse the Services, but some features may not function.
  • Industry Opt-Outs. You can control how participating third-party ad companies use the information that they collect about your visits to our websites and those of third parties. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at:
    1. In the US: Digital Advertising Alliance (DAA) You may also download the DAA AppChoices tool (https://youradchoices.com/appchoices)  in order to help control interest-based advertising on apps on your mobile device.
    2. In Europe: European Interactive Digital Advertising Alliance (EDAA)
    3. In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC) / Choix de Pub: l’Alliance de la publicité numérique du Canada (DAAC)

These preferences are browser and devices specific. You will need to set your preferences for each browser and device you use

  • Email Communications. 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 Policy or EULA.
  • Public and Private Videos. If you do not wish to share any User-Generated Content you have made, you may choose not to. By clicking on “Private” when you publish your content the video will be displayed for you only.
  • Camera. If you do not want the Services to have access to your phone’s camera, you can disable the access when prompted or in the settings menu of your phone. Please note that if you disable the camera the Services will not work as intended and you will lose access to functionality such as creating animations from your movements or creating a character from a photo of you.
  • Microphone. If you do not want the Services to have access to your phone’s microphone, you can disable the access when prompted or in the settings menu of your phone. Please note that if you disable the microphone the Services will not work as intended and you will lose access to functionality such as recording your voice or sound while creating videos.
  • Contacts. If you do not want the Services to have access to your contacts, you can disable the access when prompted in the app.
  • Access to Photos and Videos. If you do not want the Services to have access to your phone’s photo library, you can disable the access when prompted or in the settings menu of your phone. Please note that if you disable the access to the photo library, the Services will not work as intended and you will lose access to functionality such as being able to save videos you have created to your phone or be able to upload music, videos or photos when creating videos.
  • Push Notifications. If you do not want the Services to send push notifications to your phone, you can disable the access when prompted or in the settings menu of your phone. Please note that if you disable the access to push notifications, the Services will not work as intended and you will lose access to functionality such as being able to get information about when other users have interacted with your content.
  • Account Information. You may access, update, or delete your account and profile information at any time by logging in to your account and updating the Personal Data we maintain. You may also request we delete your account information on your behalf. We will delete your Personal Data within 30 days upon such request.
  • Android Ad-ID. You may choose not to consent to the collection of Android advertising ID, by either customizing this at registration or by going into Settings/Privacy.

8. Your rights (EEA only)

If you are located in the EEA, you have certain rights related to your Personal Data and how we handle it in accordance with the GDPR. Please note that your rights are not absolute. As such, a request may not lead to any action from us.

Right of access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. 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 contacting us at privacy@frever.com. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we will not be able to provide all the information you ask for, for instance if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.

Right to correct Personal Data. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.

Data deletion. You have a right to have some of the Personal Data that we hold about you deleted. Should you wish to have any information about you deleted, please contact us at privacy@frever.com. Please note that in order to process your request you may have to delete our app from your mobile devices and clear our cookies from any device where you have used our app in a web browser. Where we delete Personal Data about you, we may still retain some or all of that information for other purposes, such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity.

Data portability. In some circumstances, you will have the right to request that data which you have provided to us is provided to you in a structured, commonly used and machine-readable format, so you can transfer this to another data controller.

Restriction of processing. In some cases, you will have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.

Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Our legal bases for Processing Personal Data above). If your interest outweighs our legitimate interest, we are obliged to cease the Processing. However, we may continue to Process your Personal Data if we can justify that our legitimate interest outweighs the intrusion into your privacy.

If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you will need to opt out of all of them individually. If you object to receive marketing communication, it will not affect the lawfulness of any Processing that happened prior to your objection.

Right to withdraw consent. 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 our Services.

Automated individual decision-making, including profiling. We do not engage in “profiling” in furtherance of decisions that produce legal or similarly significant effects.

Complaints. If you believe that our Processing of your Personal Data is in breach of applicable data protection legislation, you can contact us as described above. You also have the right to lodge a complaint with the Data Protection Authority in your country.

9. External Links and Features

Our Site and Services may contain links to third-party websites or features. Any access to and use of a linked website or feature is not governed by this Policy and is instead governed by the third party’s privacy policy. We are not responsible for the information practices of such third parties, including their collection of your Personal Data. We recommend reviewing third parties’ privacy policies and terms before using those sites.

10. Security

We use reasonable security 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. Please be aware that despite our efforts, no data security measures can guarantee security.

11. Children’s Data

You must be thirteen (13) years of age or older to use our Services (or the minimum age at which a person may use the Services in your state, province, or country without parental consent, if greater). Our Services are not designed for children, and we do not knowingly collect Personal Data from children under the age of 13. If we learn that we have received Personal Data directly from a child who is under the age of 13, we will delete such information from our systems. If you are a parent or legal guardian and you believe we have collected your child’s Personal Data, please contact us at privacy@frever.com.

12. Changes to this Policy

We may update this Policy from time to time. If we do, we will post the revised version here and change the “last updated date” at the top of the Policy. You should check here regularly for the most up-to-date version of this Policy.

13. Contact Us

If you have questions about how we process your Personal Data, please contact privacy@frever.com.

14. Service Partners

The Information you either provide to us or we Process automatically may be Processed through other companies, agents or contractors . 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 Services. However, at the time of latest update of this Privacy Policy the Service Partners listed below will automatically Process Information when you enter into the EULA. See the list of Service Partners and the respective Information they Process below:

When interacting with iOS/Android Services

  • Amazon Web Services (“AWS”) (Amazon Inc.), is a mobile development platform that helps us build and run our Services. AWS is hosting our databases and servers. AWS will Process Personal Data insofar as Contact Information and Other Identifiers, User-generated content, Device and Browsing Data, Activities and Usage Data and Location information.
  • Unity 3D (Unity Technologies ApS.), a game engine platform that help us build and run our Services. Unity requires access to some technical Information about your device in order for our Services to function. Unity may Process Personal Data insofar as Device and Browsing Data.
  • Amplitude (Amplitude Inc.), an analytics service that helps us analyze user behavior on our Services in order to improve our Services and personalize your experience. Amplitude will Process Personal Data insofar as Location information, Activities and Usage Data and Device and Browsing Data.
  • Fivetran (Fivetran Inc.) a data extraction service that help us migrate data to our data warehouse in order for us to analyze user behavior on our Services in order to improve Services and personalize your experience. The Information Processed by Fivetran may constitute Personal Data insofar as Contact Information and Other Identifiers and Location information.
  • Twilio (Twilio Inc.) a SMS service that helps us send authentication messages to phones. The Information Processed will contain Personal Data in the form of phone numbers.
  • Sentry (Functional Software Inc.) an analytics service that helps us analyze user behavior on our Services in order to improve our Services and personalize your experience. Sentry will Process Personal Data insofar as Location information, Activities and Usage Data and Device and Browsing Data.
  • Hive (Castle Global, Inc.) a moderation service provider that helps us analyze user-generated content in order to make our Services safer as well as to ensure compliance with our EULA. Hive will Process Personal Data insofar as User-Generated Content.
  • Abstract API (Abstract Inc.) an API service that helps us understand which country you are currently in. The Information Processed by Abstract may constitute Personal Data insofar as Location Information.
  • OneSignal (OneSignal Inc.) a push notification provider that helps us send out push notifications. OneSignal will Process Personal Data insofar as nickname and text messages.

When interacting with web Services and other Services

  • Google Analytics (Google Inc.), an analytics service that helps us analyze your behavior in our web Services in order to improve our web Services, personalize your experience with our Services as well as to personalize interest-based ads. The Information Processed may contain Personal Data such as Ad data.
  • Facebook Business Tools (Facebook Inc.), an analytics service that helps us analyze your behavior in our web Services in order to improve our web Services, personalize your experience with our Services as well as to personalize interest-based ads. The Information Processed may contain Personal Data such as Ad data.
  • Loopia (Loopia AB), a hosting provider that allow us to host our web application. The information submitted can include Personal Data insofar as name and email.
  • G-Suite (Google Inc.), a business tool service that helps us send/receive emails to communicate with you with regards to our Services. The Information processed may contain Personal Data such as name and email.
  • Abstract API (Abstract Inc.) an API service that helps us understand which country you are currently in. The Information Processed by Abstract may constitute Personal Data insofar as Location Information.
  • TikTok (TikTok Technology Ltd.) an analytics service that helps us analyze your behavior in our web Services in order to improve our web Services, personalize your experience with our Services as well as to personalize interest-based ads. The Information Processed may contain Personal Data such as Ad data.
  • Amplitude (Amplitude Inc.), an analytics service that helps us analyze user behavior on our Services in order to improve our Services and personalize your experience. Amplitude will Process Personal Data insofar as Location information, Activities and Usage Data and Device and Browsing Data.

When interacting with Android Services

  • AppsFlyer (Appsflyer Ltd.) A mobile attribution service provider that help us analyze the performance of our marketing campaigns. AppsFlyer may Process Personal Data insofar as Ad-data.