Last updated: 2020-09-24
“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
“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.
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.
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 we Process through third-parties:
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.
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 email@example.com
Our disclosure, transfer, retention and sharing of Information
We disclose your Information for certain purposes and to third parties, as outlined below:
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
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.
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.
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.
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.
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 firstname.lastname@example.org. 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.
Cookies and Advertising
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.
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:
In the US: Digital Advertising Alliance (DAA)
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.