Privacy Policy

PRIVACY POLICY

Effective Date: February 6, 2020

This Privacy Policy describes how Frismos, Inc. (“Frismos“, “frismos“, “We”, “Us”, or “Our”) protects your privacy when you use Frismos (the “Frismos Service”) which includes the Web site located at www.frismos.com (the “Site”) and all Frismos mobile phone applications (“Mobile”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE FRISMOS SERVICE, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS DESCRIBED HEREIN AND ALL TERMS AND CONDITIONS INCORPORATED BY REFERENCE. THIS PRIVACY POLICY IS PART OF AND INCORPORATED INTO FRISMOS’S TERMS OF USE (“Terms of Use”). IF YOU DO NOT AGREE TO ALL OF THE TERMS AND CONDITIONS SET FORTH BELOW, YOU MAY NOT USE THE FRISMOS SERVICE.

For more information on Interest-based Advertising and your choices regarding it, click here.

This Privacy Policy applies to the information (including personal information) collected through the Frismos Service.

THE WHAT & HOW OF INFORMATION WE COLLECT

Automatically collected data (such as IP Address, your device’s operating system, browser type and language)

Mobile device identifiers (such as your unique device ID (persistent/non-persistent), hardware type

General location information for the purpose of providing you with the correct version of the application

Applications and games data (such as your interactions with the application or game and with the other users or players inside the application or game respectively via server log files, your user or player ID)

Frismos as Data Controller does not and will not process any special categories of personal data (“sensitive data”).

STORAGE OF INFORMATION & TRANSFER OF DATA

If you are using the Frismos Service from a country other than the country in which our Web servers are located (currently the United States of America) the various communications will necessarily result in the transfer of information across international boundaries.

HOW WE USE YOUR INFORMATION

We use information collected through the Frismos Service:

  • to communicate with you or third parties;
  • to process your requests and transactions;
  • to provide and improve the Frismos Service;
  • to customize the services and/or products we provide to you;
  • to assist with our product and service development;
  • to perform marketing activities;
  • to provide relevant advertising;
  • for other purposes related to our business;
  • to protect the security of our interests, including our premises, assets, and systems;
  • to comply with the law; or
  • as otherwise disclosed at the time personal information is collected.

WITH WHOM WE SHARE YOUR INFORMATION

Information collected through the Frismos Service may be shared with companies and organizations that perform services on our behalf (for example, companies that provide data management or other support services to us such as data storage and Web hosting services). We may share your information with third parties to serve you relevant advertising and market our products.

Also, we may disclose the information we collect through the Frismos Service when we, in good faith, believe disclosure is appropriate:

  • to comply with applicable law (e.g., in response to a valid court order or subpoena);
  • to prevent or investigate a possible crime, such as fraud or identity theft;
  • to enforce the Terms of Use or other agreements that govern your use of the Frismos Service and/or our services;
  • pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties;
  • with your consent or as otherwise disclosed at the time of data collection or sharing; or
  • to protect the rights, property, vital interests, or safety of us, our users or others.

We share information that has been de-identified or aggregated without restriction.

We may disclose your information without giving you prior notice if we believe it is necessary to prevent imminent and serious bodily harm to a person. Nothing in this privacy policy is intended to limit any legal objections or defences you might have to efforts by third parties to compel disclosure of your information, including legal orders from the government.

Your information and other data collected by us may be transferred to another company that has acquired our stock or assets, for example, as a result of a sale, merger, reorganization, dissolution or liquidation.

HOW LONG WE RETAIN YOUR INFORMATION

 

We retain your information for as long as is needed for the stated purpose. However, the retention period also depends on the need to respond to the Data Subjects’ queries and resolve problems as well as on legal requirements for retaining certain documents.

When we no longer need Personal Data to provide Services and there are no statutory obligations for retaining the relevant data, we will delete such Personal Data. We may still use such data for statistics, but in that case it will be pseudonymised or anonymised.

CONTROLLING AND MODIFYING YOUR INFORMATION – OPT-OUT / OPT-IN

We respect your right to control and make choices about your information. You may request Frismos to:

  • provide you with information we collect about you;
  • transfer your information to another controller of your choice, when technically feasible;
  • delete (please see below for more details on deletion);
  • update, edit or modify your information; or
  • change your privacy preferences at any time.

Your request can be made by emailing us at [email protected] or, in some instances you may also do it yourself via the Frismos Service.

We believe that you proceed to use our Frismos Services upon accepting all the terms in our Terms of Use, which incorporate also the terms of this Privacy Policy. And as such we have your consent in processing and using your data as defined above. However, you are also free to choose to withdraw your consent and request us to cease processing your information by sending us a notice. In such case your withdrawal will not affect the legitimacy of the prior data processing.

You may also opt-out of receiving promotional communications from us, including, but not limited to, promotional emails, by emailing us at [email protected]. Transactional service communications (such as messages about your registration) are not subject to the foregoing opt-out procedures, as are necessary for the regular conduct of our business records.

DIGITAL ADVERTISING & ANALYTICS

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

Frismos adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity. You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt-out of this advertising on websites by companies participating in the DAA self-regulatory program and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://optout.networkadvertising.org/?c=1.

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. Frismos uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt-out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

SECURITY OF YOUR INFORMATION

Keeping Personal Data secure is a topmost priority for Frismos. We do our best to protect your information from unauthorized access or against loss, misuse or alteration by third parties, disclosure and other improper processing activities.

We have put in place reasonable and appropriate organisational, technical and physical procedures and safeguards to protect the information we collect and process. These procedures also take into account the type of personal data and the risks related to its possible disclosures. In the following, we bring out specific actions with regard to organisational, technical and physical safeguards in place at Frismos.

POLICY REGARDING CHILDREN

We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.

CONTACT US

For questions or concerns about Frismos’s privacy policy or practices, please email [email protected]

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy that we think materially alter your rights, then we will post the latest policy to this site and change the “Last Updated” date above. We encourage you to review this Privacy Policy whenever you visit the Frismos Service to understand how your information is used.