Last updated: 2023-03-02
“Products” means our iOS or Android app “Frever” and our websites frever.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” or “Process” 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.
You must be 13 years of age or older to use our Products. Parents should contact us immediately if they have any concerns regarding the Products using the email below.
If you have general questions about how we use, Process and Process your personal data, please contact email@example.com. The data controller of your Personal Data is Frever AB.
We use reasonable logical, physical, admin 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.
Our Processing of Information
Information you provide to us
We Process Information you provide to us through our Products which may include:
- User account data: nickname, birthday, email address, gender, and telephone number.
- Your user-generated content: voice recordings, face animation recordings, audio files, photos, videos, text 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, when you register for early access 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:
- User interactions data: Your activity on the Products, such as page visited, button clicks, characters created, progression, assets selected, status, videos created, purchase history, number of logged-in sessions, interactions with our notification messaging such as open/read ratio, time of opening;
- Geographical data: Your country, city, region, and carrier, based on your SIM card and/or IP address.
- Customer support data: 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;
- Technical data: Uniquely assigned and randomized device and software identifiers (generated through MAC, or IMEI-numbers), screen size, device model, GPU/CPU model 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:
When interacting with iOS/Android Products:
- 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 Process Personal Data insofar as User generated content, User account data, User interactions data and Geographical data.
- 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. Unity may Process Personal Data insofar as Technical data.
- Amplitude (Amplitude Inc.), an analytics service that helps us analyze user behavior on our Products in order to improve our Products and personalize your Product experience. Amplitude will Process Personal Data insofar as Geographical data, User interactions data and Technical 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 Products in order to improve Products and personalize your Product experience. The Information Processed by Fivetran may constitute Personal Data insofar as User account data, Geographical data.
- 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 Products in order to improve our Products and personalize your Product experience. Amplitude will Process Personal Data insofar as Geographical data, User interactions data and Technical data.
When interacting with Web Products and other Services:
- Google Analytics (Google Inc.), an analytics service that helps us analyze your behavior in our web Products in order to improve our web 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 Ad data.
- Facebook Business Tools (Facebook Inc.), an analytics service that helps us analyze your behavior in our web Products in order to improve our web Products, personalize your experience with our Products 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 Products. The Information Processed may contain Personal Data such as name and email.
- Abstract API (Abstract Inc.) a business tool service that helps us analyze your behavior in our web Products in order to improve our web Products. The Information Processed by Abstract may constitute Personal Data insofar as Geographical data.
Our use of Information and Personal Data
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 violating the EULA);
- 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 Personal Data
Context 1: When you use our Products:
- We will Process Personal Data insofar as User account data, Geographical data, User interactions data and User generated content where we need the Personal Data to perform a contract with you or a third party (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 insofar as User account data and User generated content 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).
- We will Process Personal Data insofar as Technical data, where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example to understand crash reports).
Context 2: When you interact with our Customer Support in relation to our Products:
- 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 Products or other matters 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 insofar as Ad 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).
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 Frever and third-parties
Geographical Storage 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).
Frever 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 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 Products 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.
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.
If you do not want the Product to have access to your phone’s camera, you can disable the access on sign-up or in the settings menu of your phone. Please note that if you disable the camera the Product 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.
If you do not want the Product to have access to your phone’s microphone, you can disable the access on sign-up or in the settings menu of your phone. Please note that if you disable the microphone the Product will not work as intended and you will lose access to functionality such as recording your voice or sound while creating videos.
Access to Photos and Videos
If you do not want the Product to have access to your phone’s photo library, you can disable the access on sign-up or in the settings menu of your phone. Please note that if you disable the access to the photo library, the Product 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.
If you do not want the Product to send push notifications to your phone, you can disable the access on sign-up or in the settings menu of your phone. Please note that if you disable the access to push notifications, the Product 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.
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 or Discord);
- 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 contacting us at firstname.lastname@example.org
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 email@example.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 our Products. You have the right to complain to a data protection authority about our Processing and use of your Personal Data.
Cookies and Advertising
- 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.
- How can I remove cookies and advertising identifiers?
To opt out of interest-based ads from Frever 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.
Frever supports the following self-regulatory programs, which provide additional privacy choices for interest-based advertising:
3. How Does Frever 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.