Last Updated 01 Aug 2019

We at Friskal Ltd. value your privacy and are committed to protect any personal data you give us.

This document describes how we collect, use, process, and disclose your information, including personal information while using our services. Friskal offers online travel and social related services and information through multiple media such as its website, mobile app, partner websites or social media. The information provided in this document is applicable to services offered through all these platforms.

I. Information we collect

There are several ways that we collect information on all the Friskal services.

• Information about you that you provide to us directly through your activity in the app, website, social media or any other platform you can use to communicate with Friskal.
• Information about you that we collect automatically when you use Friskal app, website, social media or any other platform you can use to communicate with Friskal.
• Information about you that we collect from external sources such as Facebook, Google or other external sources which are used in Friskal app, website and other platforms.
• Information about others that you provide to us through your activity in the app, website, social media or any other platform you can use to communicate with Friskal.

II. What do we do with the collected information?

What kind of information do we measure, count, keep, save?

1. Measurements: We processes the following
   • Likes on experiences
   • Views on experiences
   • Likes on Tips/comments
   • Number of followers
   • Number of users you follow (Following)
   • Experiences created
   • Tips/Comments on experiences
   • Tips/Comments on places
   • Shares to other media
   • Ad views and visits
   • Reports concerning you
   • Reports concerning other users
2. We porcessed the following data:
   • User profile settings
   • Experiences created by user. Every experience contains the following data:
     • Author, user that created the experience
     • Title
     • Places
     • Types of places
     • Other place related data
     • Directions
     • Description
     • Hashtags
     • Time of creation
     • Photos uploaded
     • Tags/description on uploaded photos
     • Likes
     • Shares
     • Views
     • Tips/comments
     • Attached Ad
   • Experiences liked by a user
   • Experiences saved by a user
   • Photos uploaded by a user for an experience    
     • Tips (comments) created by user and timestamps
   • Places saved by a user
   • Users and usernames reported by the user
   • User follow/unfollow events
   • Place related information
     • Number of experiences the place is in
     • Place page views
     • Place photos added by users
     • Tips/comments added by users
3. Location data
   We obtain user location for:
   • Providing “near me” experiences on Discover page, search feature and Activity feeds
   • Showing users’ position on map
4. Notifications
   We keep and process some notification data for the following events:
   • User follow events
   • users’ interactions with own or other user experiences (liked, saved, commented)
   • General and App promoting notifications (reminders such as “you have an unfinished experience waiting to be published”)
5. Firebase or other analytics platforms. We use these platforms for debugging, crash reporting, improving application’s performance purposes. We keep and process the following information:
   • Number of app users and app sessions
   • Session timeframe (start/end time, duration)
   • Operating systems
   • Device models
   • Geography
   • First launches
   • App opens
   • App updates
   • Log in/Log out events
   • User IP
   • Screen view counter
   • Crash events (reason, Screen view, timeframe and other useful data)
   • User acquisition method (origin e.g. app store, link or ads)
   • Notification analytics (Number of notifications and user interactions with them, did or did not open etc.)
   • Search events
     • Timestamp
     • Search data (keyword, type, hashtag, place, user and location)
   • Share events
     • Timestamp
     • Sharing info (via sms, mail, messenger etc.)
6. User status. We follow and keep information related to user current status
   • Active
   • Inactive
   • Reported
   • Blocked/deleted
7. Registration/User Identification Data
   • Info we take from Facebook: Display name, Facebook photo, email.
   • Info we take from Google: Display name, Google account photo, email.
   • Info we take from mail login: Display name, email, profile photo added.
8. Ads. We keep and process the following information concerning the Advertisements used in Friskal across all the platforms
   • User interaction with an Ad (view, visit)
   • Type of Ad the user interacted with (Title, type, hashtag, location, target website or app)
   • Number of visited ads
9. Cookies. We use cookies on Friskal website to observe the performance of our websites, for analytics and for advertising purposes.

We use, store and process the information collected from our users for the following reasons:

1. To provide you with all the Friskal app and website features and uses.
2. To manage your account at Friskal and let you have access to our platforms
3. For marketing purposes:
   • In order to keep our Ad platform running and provide the usability needed. 
   • To conduct marketing campaigns needed to enhance our platform
4. To improve our services: We use analytics, to research and provide reports used to solve problems and make our platform better.
5. For legal purposes: In the case of legal disputes or when needed by law enforcement.
6. To communicate with you when needed for:
   • Support, technical issues, or in case of emergency.
   • Legal and law enforcement purposes.
   • Getting feedback to help us improve our tools and services.
   • Marketing purposes such as promoting new features, apps, tools, platforms, or giving you useful information and tips about the usage of Friskal and our tools.

You can unsubscribe from our mailing lists whenever you are not in need for those services, though we may communicate with you in case of emergency or severe technical issues.

III. How and why do we share your data?

We can share your personal data with third parties in the following cases:

1. With other Friskal users or people who have access to our application, website, social media or other ways and platforms we can do so, such as real life events, publications or other media.
   • We can share all the experiences, comments and other content created by you in our application or website as it is public information.
   • We can share your display name and photo as it is public information
   • We can share your interactions inside the app or website (Likes, tips, follows, followed by or other similar) as it is public information.
2. Business and Marketing partners: for some purposes we may need to share your data with business or marketing partners or other kind of partners that might need some of your personal data. These partners will be bound by confidentiality agreements and will not be allowed to use any of your data for purposes other than as specified by us.
3. Payment Partners: We may use payment partners to conduct sales through our application or website.  These partners may need your data, such as your name, address, transaction details or others, in order for the payment to be completed.
4. Google: We share Google analytics data with Google or their partners to help them improve their service to us, for technical support and growth predictions. These are anonymous data concerning the use of our application.  You are protected by these uses under the Google analytics privacy policy.  We may at some points use alternative analytics and prediction platforms such as Sentry or other platforms.
5. Authorities and law enforcement: We may need to disclose personal data to the authorities or law enforcement agencies upon request if anything occurs. This might be strictly necessary for prevention, detection or prosecution of criminal acts or fraud or if we are legally obliged to do so.

IV. Our policy on children data

The Friskal services are not intended for use by children under 13 years old and we do not intentionally collect or retain personal information from them. If you are a parent or guardian and discover that your child under the age of 13 has obtained an account or has used our services, you may contact us at support@friskal.com and request to delete that child’s personal information from our system.

V. How do we keep your data safe?

We take all reasonable measures to prevent any unauthorized access to your personal data that are being kept in our system. All data is secured on Google and Google Firebase servers. Only their authorized personnel are permitted to access your personal data during their course of work.

Data Encryption and Security

All Transmitted data are encrypted through SSL/TLS and logically isolated. Data at rest are also encrypted in Firebase servers as a service provided by Google. For more information refer to https://firebase.google.com/support/privacy.

Generally, we use your personal data for the above-mentioned purposes – to provide the Friskal services to you, to resolve disputes, to detect and prevent fraud, to comply with law enforcement and other authorities, and to conduct our business in a fair manner. Considering all these, we will hence retain your personal data for as long as we deem it necessary. All personal data we retain will be subject to this Privacy Policy.

VI. What control do you have upon your data?

1. You have total control on your Friskal account information.  You may review, update, or delete the information from your Friskal account by logging into your account and reviewing your profile details and settings.
2. You can delete your Friskal account whenever you desire by sending an email on support@friskal.com requesting the deletion of your account. Please use the subject “Delete account”.
3. You can exercise your right to rectify inaccuracies or complete any incomplete personal data by contacting support@friskal.com requesting personal data rectification. Please use the subject “Rectification of personal data”.
4. Under certain circumstances you can have a copy of the personal data we hold about you by contacting us on support@friskal.com requesting a copy of your personal data. Please use the subject “Request for copy of personal data”.  Please give us some reasonable time in order to comply with your request.
5. Under certain circumstances you can restrict the processing of your personal data by contacting us on support@friskal.com requesting this restriction. Please use the subject “Restrict the processing of my personal data”.
6. You can exercise your right to object to our processing of your data for direct marketing purposes by contacting us on support@friskal.com requesting this restriction. Please use the subject “Object to direct marketing”.
7. Under certain circumstances, you can ask us to send you your personal data that is transferred to a third party by us.
8. You have the right to withdraw your consent to us on by contacting us on support@friskal.com.

VII. Data Transfer and Retention

All the data are stored in Google’s Firebase servers which is certified under the Privacy Shield framework. The European Commission concluded that the EU-U.S. Privacy Shield Framework provides an adequate mechanism to allow EU companies to comply with requirements under the Directive in connection with transfer of personal data from the European Union to the United States. Google LLC is certified under both the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. For more information refer to https://firebase.google.com/support/privacy

We discard your data when is no longer necessary for providing you with our Services or when your account is deleted. For satisfying regal needs, improving users’ security and preventing fraud and abuse, we retain your deleted data for an extended predefined period of time.

VIII. Modifications made on this Privacy Policy

We reserve the right to modify this Privacy Policy at any time at our disposal. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Platform and update the “Last Updated” date at the top of this Privacy Policy. You may cancel your account in case you do not agree to our Privacy Policy. If you do not cancel your account, this automatically means that you agree to these terms as laid out in the Privacy Policy.

IX. Contact Information

If you have any questions about this Privacy Policy, you may contact us at our office in Cyprus:

Konstantiinou Leventi 3,

2450, Kato Deftera,

Nicosia

Cyprus

You may also mail us at support@friskal.com