Welcome to the FRIENDJI Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our brilliant T&C’s. Whilst you’re enjoying the FRIENDJI mobile application (“App”), we collect some information about you. In addition, you may choose to use the App to share information with other uses, including your friends and contacts (“Users”). We may also need to share your information sometimes.

FRIENDJI is a global service, and your information will be sent to and used in Spain regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

If you have any questions or comments about this Policy, please feel free to contact us at [email protected]

1. Collection of Information

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as: Name; Surname; Email address; Mobile number; Gender identity; Date of birth; Sexual preference; Photographs; Location; and Login information and friend lists for social media accounts that you connect to your FRIENDJI Account (this could include, for example, your Facebook and Instagram accounts (“Social Media Accounts”).

You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your “Edit Profile” page! You control your user profile and are able to correct or update (other than your email address, date of birth, gender) your information at any time by just logging in to FRIENDJI.

The information we collect helps to enhance the FRIENDJI service and verify our Users (Machines are not welcome!!). Registration Information such as your name and username may be visible to the public on your profile page.

Additional Information

We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any of our loyalty programs, sending gifts or delivery of merchandise.

We may also collect additional information in connection with your use of FRIENDJI, for example if you use our electronic messaging function.

If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information on your profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on FRIENDJI may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other users.

When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on FRIENDJI. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account – we really don’t want to have to do this so please play by the rules!

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake FRIENDJI accounts being created which can be used for malicious activities and cybercrime – they threaten the FRIENDJI network and ruin things for everyone.

To prevent abuse of the app/site, FRIENDJI uses manual decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact FRIENDJI to contest the decision.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address to send you information on these. You can withdraw this consent at any time by contacting us via email.

Data Storage

By using the FRIENDJI service, you acknowledge that FRIENDJI is a global app operating through servers located in a number of countries around the world, including the United Kingdom. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

Geolocation Information

If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalise the service and make it easier for you to interact with other Users, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, FRIENDJI
2. Android — settings, location, FRIENDJI, permissions, location

Log & Usage Data

We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted by applicable law.

In practice, we delete or anonymise your information upon deletion of your account (following the safety retention window), unless:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on FRIENDJI including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Cookies

Our cookies are small data files that are transferred to your computer’s hard disk and are basically a tool that stores information about website visits, recognises you and your preferences each time you visit FRIENDJI, and ensures site functionality and enables us to provide the services our members request.

The cookies we collect enable us to learn how people interact with FRIENDJI, which in turn helps us make a better product for you! Cookies store information about your website visits and can recognise you and your preferences each time you visit the FRIENDJI site. They help us to provide a better service to you!

FRIENDJI’S use of cookies and local storage devices is basically related to the performance of FRIENDJI’S site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members and visitors.

Below is a table to explain FRIENDJI’S cookie functions and why they’re used.

If for any reason you decide that you do not want all of your FRIENDJI activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features FRIENDJI offers!

We use the following types of cookies:

• Cookie Functions
• Cookie Purposes

Analytics and research

We use Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information, please visit Google’s Privacy Policy page.

Performance

We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests – no one likes slow pace technology!

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. Please visit this page regularly so that you are aware of any changes.

If you would like to know more about these clever and inedible cookies, including flash cookies/local storage devices, the following websites provide useful information: www.allaboutcookies.org

2. Usage of Information

Our main goal is to ensure your experience on FRIENDJI is an enjoyable one. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

• offer you our services and features;
• contact you with information about the App (e.g., updates and new offerings);
• personalise the App and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App;
• resolve disputes between you and other Users; and
• investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.

3. Disclosure of Information

Our policy is to not disclose your Registration Information, except in the limited circumstances described here:

Consent – If you consent, we may share or disclose your Registration Information, such as when you use a third party web client or application to access your Account.

Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information with these third parties, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products.

Moderators – To monitor activity on the apps and approve content.

Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.

Law and Harm – We think it is very important that all FRIENDJI’S behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.

Business Transfers -In the event that FRIENDJI or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

4. What others may see about you

We think our users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.  May be viewed and shared by users with individuals who may or may not be Users or via third party applications at our discretion. For example, a User may recommend you as a pair to his or her Facebook friends by sharing your picture, regardless of whether such friend(s) is also a User of the App. You might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.

When using FRIENDJI, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-Users of the App. We want our users to be careful about posting information that will eventually be made public.

5. Modifying your Registration Information

You may access or modify the Registration Information you provided at any time or permanently delete your Account (we hope you don’t!)

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse of FRIENDJI by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our insert our T&C’s and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.

6. Our policy towards age and realness

Although we want as many people as possible to enjoy our platform, you have to be at least 18 years old to use the App, mobile web app and web version.

During the registration process FRIENDJI will need to age estimate you based on your facial image, and check that you are a real, live person. This is so that we not only know you are a real person but it also helps protect you and the FRIENDJI community. To do this we collect a selfie from you during your account registration and authentication process. We share only your selfie with Yoti Limited, an English company. We share nothing else with Yoti and Yoti will have no way of linking your selfie to any other data about you. Yoti processes this data in its UK based servers and returns an estimated age and liveness result to us. Yoti deletes your selfie immediately once the age estimation is completed and does not use your selfie for any other purpose at all.” Here is a link to the Yoti age verification technology should you wish to know more. www.yoti.com

If you fail the Yoti age/realness test one of our team will be in touch with you to ask for government identification. Eg, Driving License, Passport or Identity card.

FRIENDJI does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from FRIENDJI. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.

7. Changes to the policy

As FRIENDJI evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at friend.app/privacy-policy. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within FRIENDJI. By continuing to access or use the App after those changes become effective, you agree to be bound by the revised Privacy Policy.

8: Security

Here at FRIENDJI we pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorised access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your device.
2. Please don’t share your social media password with anyone else.
3. We recommend you change your social media password periodically.

If you ever think someone has had access to your social media passwords, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORISED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

12: About Us

Your access to the FRIENDJI service, as well as this Privacy Policy are governed and interpreted by the laws of the Spanish government, other than such laws, rules, regulations and case law that would result in the application of the laws of the Spanish government. By using the service, you are consenting to the exclusive jurisdiction of the laws of the Spanish government. You agree that such courts shall have in personam jurisdiction and venue and waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail. The Privacy Policy constitute a binding legal agreement between you as user (“you”) and the FRIENDJI Group (“we” or “us”).

Effective Date

The Terms were last updated on: 30st May 2021.