PRIVACY POLICY

​PRIVACY NOTICE

Last updated April 15, 2020

Thank you for choosing to be part of our community at Sykori, doing business as Framr (“Framr”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us on the email provided below.

When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our App and our services.

This privacy policy applies to all information collected through our mobile application, ("App"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

 

TABLE OF CONTENTS 

1. WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

2. HOW DO WE USE YOUR INFORMATION?

3. HOW DO WE STORE YOUR INFORMATION?

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

5. WHO WILL YOUR INFORMATION BE SHARED WITH?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

8. PRIVACY POLICIES OF OTHER WEBSITES AND THIRD PARTY PROVIDERS

9. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

10. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO WE MAKE UPDATES TO THIS POLICY?

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

1. WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

Personal information you disclose to us

In Short:We collect personal information that you provide to us such as name, email, passwords and social media login data.  

We collect personal information that you voluntarily provide to us when registering at the App, when participating in activities on the App (such as creating frames, posting photos/videos, liking, commenting and sharing content), signing up for our newsletter or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the App. The personal information we collect may include the following:

  • Name as provided by you (this can be your real name, business name or alias)
  • Username (unique handle)
  • Password
  • Email address
  • Phone number
  • Social media login data: We provide you with the option to register using social media account details, like Google, Facebook or other social media accounts. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

Information automatically collected

In Short:Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use our App.

We automatically collect certain information when you visit, use or navigate the App. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes. 

This information does not reveal your specific identity (like your name or contact information) but may include the following:

  • Device information, such as your mobile device ID, model and manufacturer, operating system, version information and IP address
  • Usage information
  • Browser information
  • Language preferences
  • Referring URLs

 

Information and access we may ask you for

In Short:We may request access to in order to run certain features in our App.

We may request your permission for the following:   

  • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, microphone, sms messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.   

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include:

  • Social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public)
  • Marketing leads and search results and links, including paid listings (such as sponsored links)

 

2. HOW DO WE USE YOUR INFORMATION? 

In Short: We use your information to fulfill our contract with you, comply with our legal obligations and for legitimate business interests.

We use the information collected via our App and website for a variety of business purposes described below. We process your information in order to enter into or perform a contract with you ("Contractual"), to comply with our legal obligations ("Legal Reasons") and for our legitimate business interests ("Business Purposes"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process
  • To send you marketing and promotional communications
  • Deliver targeted advertising to you
  • To protect our App and Services, e.g. fraud monitoring and prevention
  • To enforce our terms, conditions and policies
  • To respond to legal requests and prevent harm
  • For other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, services, marketing and your experience.

 

3. HOW DO WE STORE YOUR INFORMATION?

In Short: We keep your information as safe as possible and for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our App and website is at your own risk. You should only access the services within a secure environment.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required by law. No purpose in this policy will require us keeping your personal information for longer than 90 days past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE? 

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

  • Consent. We may share your data if you have given us specific consent to use your data in a specific purpose.
  • Performance of a Contract. Where we have entered into a contract with you, we may share your data to fulfill the terms of our contract.
  • Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

We may need to process your data or share your personal information in the following situations:   

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the App, which will enable them to collect data about how you interact with the App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
  • Other Users. When you share personal information (for example, by posting comments, photos/videos or other content to the App) or otherwise interact with public areas of the App, such personal information may be viewed by all users and may be publicly distributed outside the App in perpetuity. 
  • Social Networks. If you register through a social network (such as Facebook), your contacts on the social network may be able to find you on our App, see your name, profile photo, and may see your activity on our App. Similarly, other users may be able to view your activity, communicate with you within our App, and view your profile.

 

5. WHO WILL YOUR INFORMATION BE SHARED WITH? 

In Short:We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

  • Advertising, Direct Marketing, and Lead Generation
    SendinBlue
  • Allow Users to Connect to their Third-Party Accounts
    Facebook account and Google account
  • Functionality and Infrastructure Optimisation
    Amazon Web Services and Firebase Hosting
  • User Account Registration and Authentication
    Facebook Login and Google Sign-In
  • Web and Mobile Analytics
    Google Analytics and Google Analytics for Firebase
  • Website Performance Monitoring
    Firebase Performance Monitoring
  • Website Testing
    TestFlight and Firebase Remote Config

 

6. WHAT ARE YOUR PRIVACY RIGHTS?

Our Company would like to make sure you are fully aware of all of your data protection rights.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.


Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log into your account settings and update your user account.

Upon your request to terminate your account, your account will be deactivated instantly and permanently deleted after 90 days. While deactivated, all comments and likes and your profile will be hidden. Photos and videos contributed will remain visible until your account is permanently deleted in 90 days. After this you cannot gain access to your profile or content anymore. We aim to delete all your data after 90 days. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.     


Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

  • Note your preferences when you register an account with the site.
  • Access your account settings and update preferences.

If you would like to exercise any of these rights, please contact us at our email provided below.

 

As a citizen of the EU you are entitled to the following:

  • The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
  • The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

 

As a resident of California you are entitled to the following:

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request removal of unwanted data that you publicly post on the App. To request removal of such data, please contact us using the contact information provided below, and include the email address or mobile phone number associated with your account, your age and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

What Are Cookies:
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

How We Use Cookies:
We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies:
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

  • Email newsletters related cookies
    This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
  • Site preferences cookies
    In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page.

Third Party Cookies:
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

For more information on Google Analytics cookies, see the official Google Analytics page.

  • Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.

 

8. PRIVACY POLICIES OF OTHER WEBSITES AND THIRD PARTY PROVIDERS

In Short: Our privacy policy applies only to our App and website, so if you click on a link to another website, you should read their privacy policy.

The App may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the App. You should review the policies of such third parties and contact them directly to respond to your questions.

 

9. HOW DO WE HANDLE YOUR SOCIAL LOGINS? 

In Short: If you choose to register or log in to our App using a social media account, we may have access to certain information about you.

Our App offers you the ability to register and login using your third party social media account details (like Google or Facebook). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you in the App. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

10. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our services are hosted on our own servers and on servers of our hosting partners. All data is stored in Europe. If you are accessing our App from outside Europe, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in Europe. 

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. 

EU-U.S. Privacy Shield Framework:

In particular Framr complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, Framr is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. 

Framr is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Sykori is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

12. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

 

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Patrick Rieger, by email at info[ad]sykori[dot]com.