Legal information

Privacy Policy

This page explains how Frizapp collects, uses, stores, and protects personal data across the app and related services.

14/04/2026FrizApp SAGLprivacy@frizapp.com

Privacy Policy of FRIZAPP

(14/04/2026)

1. Preliminary Provisions

(a) General Provisions

FrizApp web and FrizApp app (hereinafter referred to as the "Site") are owned and operated by FrizApp SAGL, based in Switzerland.

We are committed to protecting the privacy of our users. We acknowledge that visitors and users of the Site care deeply about their privacy, as well as the confidentiality and security of their Personal Data.

We will collect, use, and disclose Personal Data exclusively in accordance with this Privacy Policy and the applicable laws in the jurisdictions in which we process Personal Data. In the event of a conflict between the provisions of this Privacy Policy and applicable laws, the legal provisions shall prevail.

The Data Controller is "FrizApp SAGL", headquartered in Mendrisio (6850), Via Nob. Rusca 2, Switzerland.

(b) Contact Information

For any questions or requests regarding privacy, you may contact us at:

Data Hosting

The data collected will be stored on Amazon Web Services (AWS) servers, located in Frankfurt, Germany. AWS complies with European security and privacy regulations and ensures that data is processed in accordance with applicable laws, including the General Data Protection Regulation (GDPR).

Storage and Distribution of Multimedia Content

Photos, videos, and all multimedia files uploaded by users are stored and distributed through Bunny.net, an external provider specializing in Content Delivery Network (CDN), storage, and transcoding services. Content is replicated across multiple regions to ensure security, speed, and service continuity, with the following distribution nodes: Frankfurt (Germany - main server), Sao Paulo (Brazil), Singapore, and New York (USA).

Bunny.net guarantees compliance with European data protection regulations, including the requirements of the General Data Protection Regulation (GDPR).

1(c) Data Protection Officer (DPO)

At present, the Company is not required to appoint a Data Protection Officer (DPO) under the GDPR. However, for any matter related to the processing of personal data, you may contact us at: privacy@frizapp.com

2. Legal Bases for Data Collection

This Privacy Policy sets out the guidelines regarding the collection and use of your Personal Data when you use the Site, other websites related to FrizApp, or affiliated sites. All capitalized terms, such as "Personal Data" and "Sensitive Data", are defined in Article 9 of this Privacy Policy.

When we collect your Personal Data, we do so in accordance with the following legal bases:

2.1 Contractual Services

By registering or accessing FrizApp (or any Linked Sites), you agree that your personal and sensitive data may be collected and used for the following purposes:

  • Account and contract management: Data is required to enable registration, access, and account management, as well as to comply with contractual obligations.
  • Provision of services: Data is necessary to provide FrizApp's functionalities, handle communications and requests, process transactions, and improve the user experience.
2.2 Legitimate Business Purposes

In addition to collecting your Personal Data for the execution of the contract and the provision of our services, we may also process it for our legitimate interests, always in compliance with the law and without infringing your rights.

These legitimate interests may include:

  • Fair and secure use of data: Your data will not be processed in a harmful manner or in violation of your fundamental rights.
  • Reasonable and transparent use: Data will be used only for purposes that are reasonably foreseeable and consistent with your use of the Site and related services.
  • Service improvement: We may use data to enhance the Site, optimize the app, improve service quality, and send you communications designed to improve your overall experience.
  • Business management: Data may be used to ensure security, prevent fraud, analyze performance, and manage our internal operations effectively.
2.3 Explicit Consent

Where required by law, your Personal Data will be collected and processed only with your explicit consent. Such consent will be requested clearly and separately for each processing activity not directly related to the contract or the legitimate interests described above.

Your consent:

  • Will always be optional and will not affect your ability to use the basic functionalities of the service.
  • Can be withdrawn at any time, without retroactive effect and without prejudice to the lawfulness of processing carried out prior to withdrawal.
  • Will cover only the specific purposes for which it is requested (e.g., personalized marketing, newsletters, advanced profiling, or data sharing with third-party partners).

If consent is withdrawn, we will immediately cease any processing of your data for the purposes associated with that consent.

3. Legal Compliance

In certain cases, we may be required to process or retain your Personal Data in order to comply with legal obligations. This may occur, for example, following requests from a court, supervisory authorities, or other competent authorities in the context of legal proceedings or official investigations.

4. Your Consent

By accessing or using the Site or the application, you consent to the collection and use of your Personal Data in accordance with this Privacy Policy.

By registering or logging in as a member of the Site or any Linked Site, you also consent to the collection and use of your Personal Data and Sensitive Data.

You always have the right to withdraw your consent:

  • You may do so by ceasing to use the Site or any Linked Sites;
  • If you hold an account, you may request its suspension or deletion at any time, either through your account settings or by contacting us at the addresses indicated in clause 1(b).

For the complete deletion of all your Personal Data, a formal request must be submitted following the procedure described in this Privacy Policy.

4bis. Minors' Access and Parental Consent

Our services are available only from the age of 14. However, for users aged between 14 and 17, specific safeguards are applied regarding the processing of their personal data.

(a) Parental Consent

In accordance with Article 8 of Regulation (EU) 2016/679 (GDPR), minors may provide valid consent to the processing of their personal data from the minimum age established by the laws of their country of residence.

FrizApp activates the minor's account at the time of registration and, as a transparency and child protection measure, sends an email communication to the parent or legal guardian, requesting parental consent for the processing of the minor's personal data.

In jurisdictions where parental or legal guardian consent is required by applicable law, such consent is necessary for the continued processing of the minor's personal data.

In jurisdictions where parental consent is not required by law, the processing of the minor's personal data remains lawful even in the absence of a response or in the event of a refusal by the parent or legal guardian, without prejudice to FrizApp's right to adopt appropriate protective measures.

(b) Limitations for Minors

To ensure the safety of underage users:

  • Within proximity-based features such as 'Around Me', adult users cannot view profiles of minors. Appropriate safeguards are applied to reduce the risk of inappropriate interactions between adults and minors.
(c) Verification and Revocation of Consent

The parent/guardian who has provided consent may, at any time, request:

  • Revocation of consent,
  • Suspension or deletion of the minor's account,
  • Access to, rectification of, or restriction of the processed personal data.

Requests can be submitted to the contacts indicated in section 1(b) of this Privacy Policy.

(d) Protection of Minors' Privacy

We adopt technical and organizational measures to protect minors from inappropriate or harmful content. In the event of violations of our guidelines, we reserve the right to suspend or delete the account.

Chats involving minors are handled using technical and organizational security measures designed to protect confidentiality and prevent unauthorized access. The Company does not engage in constant or systematic monitoring of private communications. Any intervention may occur only in the event of reports of inappropriate or unlawful behavior, or where required by applicable law, and is based on available information such as metadata or content voluntarily provided by users (for example, screenshots).

(e) Accuracy of Information

The user (or the parent/guardian) declares that the information provided during registration - including age and parental contact details - is true and accurate.

FrizApp SAGL is not responsible for false or misleading declarations made by minors, while the Company remains committed to taking all reasonable measures to verify both age and parental consent.

5. Anonymity

Due to the nature of the services offered by FrizApp, we cannot provide our services without knowing your full name. During registration, you will be required to provide truthful, accurate, and up-to-date personal information, which is necessary for the creation and management of your account.

6. Data Collection

(a) All Users

Each time you visit the Site (even if you are not registered), our servers automatically collect certain statistical and security-related information about your use of the Site, such as:

  • the type of browser used;
  • the referring URL;
  • the IP address;
  • the number and type of pages visited;
  • the date and time of the visit;
  • the exit URL.

This information is not considered Personal Data and is processed anonymously. It is not linked to Personal Data unless you register or log in as a member. If you do not log in, we are unable to associate such data with your identity.

Registered Members

Legal Basis for Processing

The collection and processing of Personal Data are carried out in compliance with the General Data Protection Regulation (GDPR) and may be based on:

  • the user's explicit consent;
  • the performance of a contract;
  • compliance with legal obligations.

Personal Data Collected

The Personal Data that the Company may collect includes:

  • first and last name;
  • email address;
  • residence address;
  • phone number;
  • one or more photographs;
  • age;
  • profession/employment;
  • description of personal appearance;
  • payment data (if provided).
Sensitive Data

In addition to basic personal data, the Company may collect and process the following Sensitive Data:

  • Religious beliefs or affiliation: processed only if the user chooses to provide such information in their profile, for personal presentation and sharing purposes.
  • Criminal record data: only if required by applicable law, e.g., users residing in the United States of America.
  • Other data necessary for the proper functioning of the app.

Such data is processed solely on the basis of the user's explicit consent and is never used for marketing purposes, commercial profiling, or any activities not strictly related to the provision of services.

By accessing and using the Site or the app, you explicitly consent to the collection and use of your Sensitive Data, as described in this Privacy Policy.

You also agree that such data may be shared with third-party service providers strictly related to the operation of the app.

Users remain solely responsible for ensuring that any content they upload, share, or otherwise make available through the Service does not infringe third-party rights, including intellectual property rights such as copyright, trademarks, or related rights.

The processing of user-generated content by the Company for technical, operational, or security purposes does not imply verification of ownership or legality of such content, nor does it constitute approval, endorsement, or assumption of responsibility by the Company.

Any issues, claims, or disputes relating to the ownership, licensing, or lawful use of user-generated content are governed exclusively by the Terms of Use and remain the sole responsibility of the user who published such content.

The Company acts exclusively as a technical hosting and processing provider with respect to user-generated content. The processing of such content for data protection purposes does not create any obligation for the Company to verify, monitor, or assess the legality, ownership, or copyright status of the content uploaded by users.

(b). Automatically Generated or Consent-Based Information

When you use our services, various types of technical and usage data are generated and collected, helping us ensure the operation, security, and improvement of the platform.

1. Usage Information

We collect data related to your activity within our services, such as:

  • date and time of access;
  • features used and actions performed;
  • content viewed and interactions with advertisements or sponsored content;
  • interactions with other users (messages sent or received, comments, likes, follows, and similar activity).

Private messages are transmitted using secure communication protocols and are stored using appropriate technical and organizational security measures aimed at preventing unauthorized access.

The chat system does not use end-to-end encryption (E2EE). The Company does not routinely access or review the content of private messages and does not engage in constant or systematic monitoring of communications.

The Company processes certain metadata related to messages (such as date and time of sending, sender and recipient identifiers, and technical delivery data) solely for the purposes of message delivery, service security, prevention of abuse, and compliance with legal obligations.

Any access to information relating to private communications may occur only in exceptional circumstances, such as user reports, investigations required to enforce the Terms of Use, or obligations imposed by competent authorities, and may be based on metadata or content voluntarily provided by users (for example, screenshots).

2. Device Information

When you access our services, we collect information from your device, such as:

  • IP address;
  • device ID and type;
  • app settings and crash logs;
  • advertising ID (resettable via your device settings);
  • identifiers linked to cookies or similar technologies.

We use cookies and related technologies (pixels, SDKs, web beacons) to recognize your device.

For more details, please refer to our Cookie Policy.

Note: We currently do not adhere to "Do Not Track" (DNT) signals, as no common standard has yet been established.

3. Automated Processes

Some processing activities may involve automated decision-making, such as:

  • connection suggestions;
  • detection of suspicious or abnormal behavior.

These processes rely on algorithmic criteria to improve the user experience and ensure platform security.

You have the right to:

  • request human intervention;
  • express your opinion;
  • contest automated decisions that produce significant effects.

4. Interactions with Other People

Information about people and accounts you share and communicate with

When you share and communicate using our Products, you choose the audience for what you share. For example, when you post on FrizApp, you can select the audience for that post (such as a group, all your friends, the public, or a customized list of people).

Similarly, when you use the chat to communicate with individuals or businesses, those recipients can see the content you send.

Your network may also see the actions you take on our Products, including engagement with advertisements and sponsored content.

We also allow other accounts to see who has viewed their stories, posts, or reels on FrizApp.

5. Public Information

The information you share publicly on FrizApp may be visible to anyone, both inside and outside the platform, including people who do not have an account.

This may include, for example:

  • your FrizApp username;
  • the data and content included in your public profile;
  • posts, reels, or other content shared on public pages, accounts, or forums.

Such information may:

  • be viewed, accessed, and reshared by other users;
  • be indexed in search engine results;
  • be made available through tools and APIs;
  • be distributed via third-party services (apps, websites, social media, TV, or other offline media).

6. Sharing by Other Users

When you use FrizApp, you should carefully consider with whom you choose to share your content or activity. People who can view what you post may, in turn, share it with others, both inside and outside the platform, including individuals or companies that are not part of the audience you originally selected.

For example:

  • A post or message sent to friends or specific accounts can be downloaded, captured via screenshot, or reshared with other users or outside FrizApp (including offline or in virtual reality environments such as Horizon Worlds).
  • When you comment on or react to someone else's content, your comment or reaction will be visible to anyone who has access to that content. In addition, the owner of the post may later change its visibility settings, expanding the audience that can view your comments or reactions.

7. Content Shared by Others About You

Other users may use our Products to create or share content about you, choosing the audience with whom to share it. For example, they may:

  • post a photo of you in a Story;
  • mention or tag you in a post or at a location;
  • share information about you in their posts or messages.

If you are not comfortable with what others have shared about you, you can report the content using the tools available on the platform, or you can contact us directly at:

FrizApp SAGL, Via Nob. Rusca 2, 6850 Mendrisio, Switzerland.

8. Activity Status Information

Users connected to your network may see indicators of your presence on the platform. These signals may include, for example, whether you are currently online on FrizApp or the last time you used our services.

9. Third-Party Apps, Websites, and Integrations

When you use third-party applications, websites, or services that integrate with FrizApp, those parties may receive certain information about what you post or share.

For example:

  • if you participate in a game with your friends or use buttons such as "Comment" or "Share" on an external website, the developer or the website may receive data related to your activity;
  • when you download or use third-party services connected to FrizApp, they may access your public profile and any information you choose to share with them;
  • if authorized by you, third-party apps and websites may receive your friends list.

However, such apps or websites cannot access any other information about your friends or followers unless those friends or followers voluntarily choose to share it themselves.

Information collected by these third-party services is governed solely by their own policies and terms of use, not by this Privacy Policy.

10. Other Information Collected with Your Consent

10.1. Geolocation Data

With your explicit consent, we may collect precise information about your geographical location (latitude and longitude) directly from your device.

Collection may also occur in the background if authorized through your device settings.

If you do not grant us permission, we will not collect location data, and some app features based on geolocation may not be available.

You can disable geolocation at any time, either temporarily or permanently, understanding that doing so may limit certain platform functionalities.

"Geolocation data is used exclusively to enable proximity-based features (such as the 'Around Me' functionality). The application does not display users' exact real-time location to other users, nor does it provide continuous tracking."

10.2. Other Multimedia Information

With your consent, we may collect additional information related to photos and videos you choose to share - for example, when you post content or participate in streaming features available on our services.

(c) Cookies and Similar Technologies

To enhance your browsing experience, we use cookies and similar technologies (such as pixel tags, web beacons, and advertising IDs).

Cookie Management

You can manage cookies through your browser or device settings.

If you disable cookies, some features of the Site or app may no longer be available or may not function properly.

You always have the option to refuse the use of cookies, but this may limit your overall platform experience.

Use of Google Analytics

Our Site and app use Google Analytics, a service that sends traffic data to Google servers in the United States.

Google Analytics does not personally identify users and does not associate IP addresses with any other data held by Google.

We use Google's reports to analyze traffic, understand page usage, and improve our services.

Users can customize or disable Google Analytics for Display Advertising through their Google account settings.

Integration with Google Marketing and AdMob

Our services may integrate cookies and tracking technologies to support Google Analytics and Google platforms for:

  • demographic and interest reporting;
  • display advertising, including remarketing and impression reporting on the Google Display Network;
  • optimizing and personalizing advertising services based on prior visits to the Site;
  • creating reports on ad usage, interactions with ads, and their relationship to visits to the Site/app.
(d) Interactions with Third Parties

We may authorize third parties - including service providers, advertising agencies, data management platforms, and advertising networks - to display advertisements on our Sites and app.

In some cases, your profile may be shared with FrizApp-affiliated companies for data analysis purposes or to optimize advertising campaigns.

Tracking Technologies Used by Third Parties

These companies may use tools such as cookies, pixel tags, web beacons, device IDs, or advertising IDs to collect information about users who view or interact with their ads.

This information is collected in an anonymous form and does not allow for personal identification.

Examples of third-party partners include: 360, Adobe, Akamai, Appnexus, Baidu, Bing, Cake, Chargeback.com, Criteo, Ecom Services, Facebook, Firebase, Google Ads, Google Ads Manager, AdMob, Google Analytics, HotJar, Index Exchange, Naver, Olark, Oracle, Publift, Pubmatic, Pusher, RayGun, Rubicon Project, SDL, Sentient, Taboola, TikTok, Twitter, Urban Airship, Visa Inc., Yahoo, Yandex, Zero Bounce.

Right to Refuse

You may refuse the collection of data by third parties by adjusting your browser settings or requesting deactivation of your profile.

Additionally, upon your first access, you may refuse non-essential cookies via the dedicated consent banner.

Access to Third-Party Sites

In certain sections of the Site, you may be redirected to third-party websites.

These sites are not subject to this Privacy Policy and are beyond our control. They may collect Personal Data independently.

We strongly recommend reviewing the privacy policies of each external site before providing personal information.

Additional Information

For complete details on the types of cookies used, their purposes, and how to manage your preferences, please refer to our Cookie Policy, available on the Site and app.

(e) Advertising

We display advertisements to users who do not have a subscription plan.

Ads are delivered via Google Ads Manager, Facebook Ads Manager, and AdMob - global advertising platforms that allow advertisers to purchase space through networks compatible with Google Ad Exchange and similar services.

We never share your Personal Data with these platforms. The only information transmitted is an Ad Token, which allows advertisers to distinguish one user from another without ever revealing their identity.

Types of Ads Displayed

The app may show two categories of ads:

  • Personalized Ads: based on user data (e.g., geographic location, declared preferences, usage behavior).
  • Non-Personalized Ads: based on generic parameters (e.g., language, feed content, app context).

Legal Basis

Personalized ads are shown only with your explicit consent, collected via the initial cookie and privacy banner.

If no consent is given, you will only see non-personalized ads.

Data Collected for Personalized Ads

If authorized, the following data may be processed:

  • Geolocation information;
  • Declared preferences and interactions within the app;
  • Browsing history and usage behavior.

Preference Management

You have the right to:

  • Access and modify ad preferences at any time via the "Privacy Settings" section;
  • Withdraw consent for personalization at any time, with immediate effect.

Data Sharing with Third Parties

Some limited data may be shared with certified advertising partners (e.g., Google AdMob) solely for the purpose of delivering personalized ads.

These partners are required to comply with GDPR and other applicable data protection regulations.

Transparency and Control

The app provides users with:

  • Clear labels distinguishing personalized ads from non-personalized ads;
  • The option to disable data collection for advertising purposes at any time via the settings menu.

Data Retention

Data collected for ad personalization will be retained for a maximum of 12 months from the last activity or until consent is withdrawn, whichever occurs first.

Non-Intrusive Ads

All ads, whether personalized or not, are designed to integrate smoothly into the app interface without disrupting the user experience.

Contact

For more information about the use of data for advertising purposes, you can contact our Data Protection Officer (DPO) at the email address listed in the Contacts section of this Privacy Policy.

(f) Social Media

Our platform may integrate interfaces with social media sites and services such as Facebook, Twitter, YouTube, Instagram, Pinterest, Weibo, TikTok, and others.

If you choose to use social features (for example, "liking" or sharing content from our Site or app), the data related to these actions may be processed by the respective social networks.

It is your responsibility to review and understand the Privacy Policies of each social media service you use.

If you have an account on a social media platform, certain integrations may allow that service to associate your activity on our Site or app with your Personal Data already available on that social network.

(g) Interactions with Third Parties

We may authorize third parties, such as advertising agencies, data management platforms, and advertising networks, to place advertisements on our Sites and application.

These companies may collect information about how users interact with their ads (e.g., views, clicks, or preferences).

The data collected is processed in an aggregated and anonymous form, without allowing the direct identification of the user.

Users can manage or limit the collection of such data through their browser or device settings, or via the cookie management options available on our Site/app.

(h) Data from Parents/Guardians for Consent

When a user declares an age between 14 and 16 years, we collect the following data from the parent or legal guardian:

  • full name;
  • email address.

This data is used exclusively for the following purposes:

  • sending the consent request for the processing of the minor's data;
  • verifying the authenticity of the consent;
  • allowing the parent/guardian to exercise their rights (revocation, modification, deletion).

The collected data will never be used for marketing, profiling, or any other activities unrelated to parental consent.

Retention period:

  • The data will be retained only for the time strictly necessary for verification and for the entire duration of the minor's account;
  • In the event of revocation or deletion request, the data will be promptly erased;
  • If parental consent is required by applicable law and is not provided within 90 days, the parent or legal guardian's contact data may be deleted and the minor's account may be suspended or deleted in accordance with applicable law.

Parent or legal guardian contact details are collected in order to send an informational communication and a request for parental consent following the activation of the minor's account. Such data is processed exclusively for child protection, transparency, and legal compliance purposes and is not used for marketing, profiling, or unrelated activities.

6-bis. Private Chats and Message Security

Private conversations between users are protected through secure transmission methods and technical and organizational security measures designed to ensure confidentiality and prevent unauthorized access.

The chat system does not rely on end-to-end encryption. Messages may be temporarily stored on the Company's systems for technical delivery, security, or compliance purposes and are protected by access controls and internal security policies.

The Company does not perform systematic monitoring of private communications and does not access message content as a regular practice.

In the event of reports concerning illegal, abusive, or inappropriate behavior, or where required by law or by competent authorities, the Company may take appropriate actions based on available information, including metadata, user reports, or content voluntarily provided by users (such as screenshots).

Users remain solely responsible for the content of their private communications.

7. Purposes of the Collection, Storage, Use, Transfer, and Disclosure of Personal Data

(a) Collection Directly from You

Whenever reasonable and practicable, we collect your Personal Data directly from you (e.g., registration, account settings, support requests, use of the app).

(b) Purposes of Collecting Personal Data

We process your Personal Data only for strictly necessary purposes ("Primary Purpose"), including:

  • Service delivery: reviewing your registration request; creating your public profile; enabling users to discover other users and connect based on shared interests, profile information, or proximity-based features; providing communication tools between members.
  • Internal portability: allowing you, if requested, to transfer your profile from FrizApp to other services/websites owned by or affiliated with us.
  • Internal analysis: statistics and research (market segmentation, customer value analysis), including aggregated/anonymous forms where possible.
  • Commercial communications: sending information about products/services/promotions unless you expressly opt out (opt-out always available).
  • Payments: processing payments through third-party providers.
  • Other purposes provided in the Terms of Use.

Sale of Personal Data

We do not sell or transfer your Personal Data to third parties for commercial purposes, except as expressly indicated in this Privacy Policy or with your explicit consent.

Payment Data Security and Liability

Payments are handled by third-party providers that comply with current security standards (e.g., PCI-DSS).

FrizApp does not store complete credit card details.

In case of suspected fraud, please contact your bank and/or the relevant authorities immediately.

FrizApp is not liable for damages arising from fraudulent use of payment tools by third parties.

(c) Use and Disclosure of Personal Data

The Primary Purpose may include automated processes (e.g., profile recommendation systems, automated content moderation).

We may use or disclose your data for Secondary Purposes only if:

  • the purpose is compatible with the Primary Purpose and, for Sensitive Data, directly connected;
  • you can reasonably expect such use;
  • you have provided specific and informed consent;
  • the use or disclosure is required or permitted by law or by an authority.

Use for Advertising Purposes (Hash and Audiences)

To improve campaign effectiveness, we may send advertising platforms (e.g., Facebook Custom Audiences) a cryptographic hash of your email address:

  • the hash is irreversible and does not allow direct identification;
  • use is limited to measuring or including/excluding in audiences;
  • no further use is permitted by the recipient platforms.

Internal Transfers (Intra-Group)

Any sharing between companies within the FrizApp group will take place only with your consent and subject to appropriate safeguards.

Withdrawal of Consent

You may withdraw your consent for Primary or Secondary Purposes at any time (see contacts in section 1(b)). Withdrawal may limit or prevent access to certain features/services.

(d) Storage and Security of Personal Data

We adopt appropriate technical and organizational measures to protect data from:

  • unauthorized access/alteration/disclosure or destruction;
  • accidental loss, misuse, or interference.

Personal Data Breach

If a breach involves a high risk to your rights and freedoms, we will inform you without undue delay and notify the Data Protection Authority, as required by GDPR.

(e) Transfer and Disclosure to Third Countries

By creating a profile, you agree that your profile information may be globally visible, including in non-EEA countries.

For customer support, back-office operations, fraud prevention, or service delivery, data may be accessible to staff/providers located outside your country.

Note on Transfers to U.S. Providers

Some service providers (e.g., Google Analytics, Google AdMob, Facebook Ads Manager) may transfer your personal data to third countries, including the United States.

In such cases, we adopt Standard Contractual Clauses (SCCs) approved by the European Commission and, where necessary, additional safeguards (such as IP anonymization) to ensure adequate data protection.

Risks and Safeguards

Transfers to countries without an adequacy decision may pose risks to data protection.

Such transfers will occur only if necessary for service delivery or with your explicit informed consent.

You may withdraw your consent for transfers at any time (see contacts in section 1(b)), though this may limit service availability.

In the absence of consent, transfers will occur only if legally required or ordered by an authority.

Basis for Transfers

Transfers to third countries, including India, are carried out on the basis of the European Commission's Standard Contractual Clauses (Article 46 GDPR), supplemented with additional measures where necessary.

(f) Unsolicited Information

If we receive unsolicited Personal Data and its collection is not compliant with applicable law, we will delete or anonymize it, unless another legal basis justifies retention.

(g) Non-Confidential Information (Published Content)

Content you publish on your profile (photos, videos, descriptions) is treated as non-confidential and non-proprietary. This classification does not affect ownership of content or intellectual property rights, which remain with the user as specified in the Terms of Use. The Company's treatment of published content as non-confidential does not imply any assumption of responsibility for the legality, ownership, or copyright status of such content.

FrizApp may duplicate and transfer your profile and associated content to other websites/platforms owned or operated by FrizApp group partners, in compliance with this Privacy Policy and applicable consents.

(h) Communications

FrizApp may send you communications via email relating to:

  • connection suggestions;
  • activity notifications (interests received, new messages);
  • promotions/offers/service updates.

You may manage your preferences at any time in the "Notifications" section of your account (opt-in/opt-out).

For marketing communications, we rely on your consent or, where applicable, our legitimate interest with a right to object (Article 21 GDPR).

(i) Automated Decision-Making and Profiling

Some app features may rely on automated decision-making, such as connection suggestions, profile filters, or detection of abnormal behavior.

No decision producing legal effects or significantly impacting your rights will be made solely through automated processing without human intervention.

You always have the right to request human intervention, express your opinion, or contest an automated decision in accordance with Article 22 GDPR.

8. Deletion of Personal Data

We retain your Personal Data only for as long as strictly necessary to achieve the purposes for which it was collected, unless longer retention periods are required by law.

We will delete or anonymize data when:

  • it is no longer necessary for the original purposes and there are no other legitimate reasons to retain it;
  • such deletion is required by applicable law or by an order from the competent authorities.

If your Personal Data has been shared with third parties, its retention and subsequent deletion will be governed by their respective data processing policies.

Specific Data Retention Periods:

  • Payment data: up to 10 years, in compliance with tax and accounting obligations.
  • Access and app usage logs: up to 6 months, for security and fraud prevention purposes.
  • Data related to reports or violations: retained for up to 3 years after the closure of the case.
  • Sensitive data, where exceptionally processed under applicable law and with the user's explicit consent, is retained for as long as necessary for the relevant purpose or until consent is withdrawn.

9. Access, Correction, Portability, and Restriction of Personal Data Processing

(a) Access to Personal Data

Upon request, we will provide you with access to your Personal Data in our possession, except in the following cases:

  • When access would be unlawful;
  • When denial of access is required or authorized by law, regulation, or order of a competent authority.

To request access to your Personal Data, you may contact us using the information provided in Section 1(b) of this Privacy Policy.

Following your request, you will receive a response within a reasonable timeframe and in any case no later than 1 month from the date of receipt of the request, subject to an extension of up to 2 months in cases of complexity. In the event of denial, you will receive written communication stating the reasons.

(b) Disclosure to Third Parties

We do not sell your Personal Data to third parties. Unless otherwise stated in this Privacy Policy, we do not disclose your Personal Data to third parties for commercial purposes.

However, you may always request confirmation that your Personal Data has not been sold, as well as details of any third-party recipients for commercial purposes, if applicable.

In some circumstances, we may share your Personal Data with third-party service providers (for the provision of FrizApp services) and with entities affiliated with or belonging to the FrizApp Group, for example, to enable the transfer of your profile across our websites and applications.

(c) Data Portability

Where the processing of your Personal Data is based on consent or the execution of a contract and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.

If technically feasible, you may request the direct transfer of your Personal Data to another data controller.

The right to data portability must not adversely affect the rights and freedoms of others.

(d) Limitations on Access to Confidential Data

Where access to Personal Data would result in the disclosure of confidential business information or trade secrets, we reserve the right to deny access, while still providing you with adequate justification.

(e) Use of Intermediaries

If we are unable to provide you with direct access to your Personal Data, we may, where reasonable, appoint an intermediary to facilitate such access.

(f) Correction and Deletion of Personal Data

You have the right to request the correction of inaccurate data and the completion of incomplete data. It is your responsibility to ensure that the Personal Data you provide is accurate and up to date.

If you are unable to correct your Personal Data directly via your account settings, you may contact us using the references indicated in Section 1(b). In case of denial, we will inform you of the reasons within 1 month of the request and inform you of the available remedies.

You also have the right to request the deletion of your Personal Data when:

  • The data is no longer necessary for the purposes for which it was collected;
  • You withdraw your consent and no other legal basis for processing exists;
  • You object to the processing and there are no overriding legitimate grounds;
  • The processing has been carried out unlawfully;
  • The Personal Data must be deleted to comply with a legal obligation.

Deleting your data will result in the removal of your profile and the termination of your access to FrizApp services.

If your data has been shared with third parties, we will take reasonable steps to inform them of your request.

(g) Refusal to Correct or Delete

If we refuse to correct or delete your Personal Data, we will inform you of the reasons and the means available to challenge the decision.

(h) Restriction of Processing

You have the right to request the restriction of the processing of your Personal Data when:

  • You contest the accuracy of the data (for the time necessary to verify it);
  • The processing is unlawful, but you oppose deletion;
  • The data is no longer necessary but is required for the establishment, exercise, or defense of a legal claim;
  • You object to processing, pending verification of overriding legitimate grounds.

During the restriction period, your Personal Data will be processed only with your consent or for legal defense purposes.

(i) Costs

Access, correction, and deletion of Personal Data will generally be free of charge.

We may charge reasonable administrative fees only if your requests are manifestly unfounded, excessive, or repetitive.

(j) Right to Object

You have the right to object at any time to the processing of your Personal Data based on:

  • Public interest;
  • Exercise of official authority;
  • Legitimate interest of the data controller or third parties.

In the event of objection, we will cease processing unless there are overriding legitimate grounds or the necessity to defend legal claims.

You also have the right to object to processing for direct marketing purposes, including profiling.

Requests to exercise these rights may be sent to info@frizapp.com

10. Complaints

(a) Filing a Complaint

If you believe that the processing of your Personal Data violates this Privacy Policy or applicable law, you may file a complaint by contacting us at:

Email: info@frizapp.com

You also have the right to lodge a complaint with the Data Protection Authority or with the competent supervisory authority in your jurisdiction.

(b) Response to Complaints

We will respond to your complaint in writing within 30 days, informing you of the actions taken or the reasons for any denial, as well as the remedies available to you.

11. Language of the Privacy Agreement

This Privacy Policy is drafted in the English language. Any translations are provided for convenience only. In the event of any conflict, inconsistency, or discrepancy between the English version and any translated version, the English version shall prevail.

12. Definitions

  • "The Company": means FrizApp SAGL, with registered office at Via Nob. Rusca 2, 6850 Mendrisio, Switzerland.
  • "Group": refers to any company, website, application, or digital platform owned, managed, or directly or indirectly controlled by FrizApp SAGL.
  • "General Data Protection Regulation" or "GDPR": means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
  • "International Organization": means an organization and its bodies governed by public international law, as well as any other body established by or on the basis of an agreement between two or more States.
  • "Personal Data": means any information relating to an identified or identifiable natural person (hereinafter the "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 their physical, physiological, genetic, mental, economic, cultural, or social identity. Personal Data includes Sensitive Data.
  • "Processing": means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • "Sensitive Data": for the purposes of this Privacy Policy, this term may include certain optional profile information voluntarily provided by the user and processed only where permitted by applicable law. The Company does not collect or process data relating to political opinions, trade union membership, health status, or other special categories of data as defined under Article 9 of the GDPR.
  • "Linked Site": means any other website, application, or online platform owned, managed, or controlled by FrizApp SAGL, with registered office at Via Nob. Rusca 2, 6850 Mendrisio, Switzerland.