Last updated March 23, 2026

This Privacy Notice for FRÅNDS ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (FRÅNDS), or any other application of ours that links to this Privacy Notice
• Use FRÅNDS. A social media app designed for absolute privacy and anti-doom-scrolling. It goes beyond the standard way of posting and creates journals for unique experiences.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at benedict.kunzmann@icloud.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We may receive fraud and security-related device intelligence from trusted service providers (for example, Fingerprint) that process data on our behalf.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• usernames

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our application(s). When you choose to share location on a post, we store the precise GPS coordinates (latitude and longitude) together with that post. Location sharing for posts is entirely optional and can be toggled off before publishing.
• Mobile Device Data. We may automatically collect device information such as your mobile device ID, model, and manufacturer, operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s).
• Device Intelligence and Fingerprinting Data. To protect accounts and prevent abuse, fraud, ban evasion, and harmful behavior, we use Fingerprint Pro (FingerprintJS). This may process technical device and network signals (for example device, app, and network metadata) and generate a pseudonymous visitor identifier. We use this only for security and fraud prevention, not for advertising personalization.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Fraud prevention provider details: Fingerprint Pro acts as our service provider/data processor for device intelligence processing. We remain the data controller for how this data is used in FRÅNDS.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To enable location-based post features. When you opt in to share your location on a post, we store precise GPS coordinates (latitude and longitude) alongside that post to support location-aware features.
• To detect, prevent, and investigate fraud, abuse, ban evasion, and other harmful activity.
• To save or protect an individual's vital interest.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent
• Legitimate Interests (including fraud prevention, abuse prevention, and service security)
• Legal Obligations
• Vital Interests

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent).

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

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

• Business Transfers
• Offer Wall
• Security and Fraud Prevention Providers (such as Fingerprint Pro), strictly to help detect abuse, account compromise, and ban evasion.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. We do not make any guarantee regarding any such third parties.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

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

Our Services offer you the ability to register and log in using your third-party social media account details. We will use the information we receive only for the purposes that are described in this Privacy Notice or otherwise made clear to you.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice.

Fraud-prevention and device-intelligence data (including pseudonymous identifiers) is retained only as long as needed for security investigations, abuse prevention, legal compliance, and enforcement of our Terms, after which it is deleted or de-identified where feasible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We also use technical abuse-prevention controls, including device intelligence/fingerprinting signals, to help protect accounts and platform safety.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

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 in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at benedict.kunzmann@icloud.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have rights to request access to and receive details about the personal information we maintain about you.

Categories of Personal Information We Collect

• A. Identifiers - Collected: YES
• B. Personal information as defined in the California Customer Records statute - Collected: NO
• C. Protected classification characteristics under state or federal law - Collected: NO
• D. Commercial information - Collected: NO
• E. Biometric information - Collected: NO
• F. Internet or other similar network activity - Collected: YES
• G. Geolocation data - Collected: YES (precise GPS coordinates, only when you opt in to location sharing on a post)
• H. Audio, electronic, sensor, or similar information - Collected: NO
• I. Professional or employment-related information - Collected: NO
• J. Education Information - Collected: NO
• K. Inferences drawn from collected personal information - Collected: NO
• L. Sensitive personal information - Collected: NO

Your Rights

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of targeted advertising, sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at benedict.kunzmann@icloud.com, or by using the contact details at the bottom of this document.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at benedict.kunzmann@icloud.com.

California "Shine The Light" Law

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 information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes.

12. DO WE MAKE UPDATES TO THIS NOTICE?

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

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at benedict.kunzmann@icloud.com or contact us by post at:

FRÅNDS App Inc.

Leipzig, Leipzig 04105

Germany

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request.