FriendWay Privacy Policy

Welcome to the FriendWay Privacy Policy (“Policy”)! This explains how we collect, store, protect and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re enjoying the FriendWay mobile application, we collect some information about you. In addition, you may choose to use the App to share information with other FriendWay members (“Users”). We may also need to share your information sometimes.

FriendWay’s App is global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

Who we are

Friendway as the data controller of the personal information collected and processed through the FriendWay App (referred to in this Policy as “we” and “us”).

FriendWay has designated a Data Protection Officer that can be reached by emailing info.friendway@gmail.com.

1. COLLECTION OF INFORMATION

Registration information

When you download the App and Login, we may collect certain information (“Registration Information”) about you, such as:

• Name;
• Username;
• Email address
• Gender identity;
• Photographs;
• Location, and
• Login information for social media accounts that you connect to your FriendWay Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking other accounts to FriendWay” in section 7 below.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who using App.

For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):

• A. Identifiers, such as name and location;
• B. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
• C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
• D. Commercial information, such as transaction information and purchase history;
• E. Biometric information, such as faceprint;
• F. Internet or network activity information, such as browsing history and interactions with our Sites and App;
• G. Geolocation data, such as mobile device location;
• H. Audio, electronic, visual and similar information, such as photos and videos;
• I. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself.

Profile Verification Information

For safety and security and to ensure you have the best possible user experience, we may require Users to verify their accounts on social media. We want to make sure you are not a robot! And we also want to avoid fake FriendWay accounts being created which can be used for malicious activities and cybercrime – they threaten the FriendWay network and spoil things for everyone. This verification might be required by us for the prevention of fraud.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

FriendWay uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact FriendWay to contest the decision.

Geolocation Information

If you have given FriendWay access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given FriendWay access to your location services, but wish to turn them off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, FriendWay
2. Android — settings, location, FriendWay, permissions, location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out here. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on FriendWay, including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Honesty Club and other Contributions

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for FriendWay). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via our Feedback Page.

When you contact Customer Support

If you contact our Customer Support team via email, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you.

2. USE OF YOUR INFORMATION

Our main goal is to ensure your experience on FriendWay is an enjoyable one and in order to deliver it to you, we may use your Registration and other information to:

• offer you our services and features;
• contact you with information about the App (e.g. updates and new features);
• to personalise the App and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App;
• test new technologies and processes designed to enhance and develop the App;
• resolve disputes, troubleshoot problems and enforce our Terms and Conditions of Use;
• investigate fraud, protect our legal rights, and to enforce our Terms and Conditions of Use;
• to send you information about the promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication - if you’ve signed up for our communications or otherwise told us it’s ok.; and
• protect our Users and third parties from harm.

Our Search Algorithms

The search algorithm operates as follows: initially, it captures the user's current position. From this position, using a radius specified in the user's settings, it identifies other users within this radius while excluding those whose distance exceeds the limit set in their visibility settings. In the final stage, users are selected based on predefined criteria, such as shared social networks and gender. All these processes are repeated every minute, taking into account the user's current location and selected filters.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

3. DISCLOSURE OF INFORMATION

Our policy is to not disclose your personal data, except in the limited circumstances described below:

MORE INFORMATION ABOUT DISCLOSURES

Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which FriendWay shares User personal data vary depending on a variety of factors, such as which of our Apps a User engages with. For example, to provide our services to FriendWay App Users, we typically use the following suppliers:

• Billing services - to allow customers to purchase paid features of our App (for example, Google Play)
• Authentication services - to allow customers to authenticate their account (for example, Apple ID)
• Social media providers - to allow customers to create/connect their FriendWay account with their account(s) on such platforms (for example Facebook or Instagram)
• Product improvement and market research - we use third party platforms and agencies to carry out customer surveys and market research to improve our products and services
• Growth marketing services - to allow us to market and advertise FriendWay to potential customers (for example Facebook)
• IT services - some of the third-party software providers used in the operation of our business may process customers’ personal data

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Marketing Service Providers and Advertising Partners

We may partner with advertising publishers to place third party adverts on our App and Sites (‘Advertising Partners’). We also partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

• to exclude you from advertising campaigns aimed at finding new users, if you already have a FriendWay account;
• to show FriendWay adverts to users who have visited the FriendWay App but haven’t yet created a FriendWay account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers hold about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive FriendWay advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with companies that help us with marketing and advertising, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer), know when an ad has been viewed or clicked on in the App or sites, and when an ad causes a “conversion” (for example downloading the app advertised to you))
• your estimated location (based on your IP address)
• gender
• data about your visit to App and action taken on those (for example if you download our App or created an Account with our App)
• a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters - this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

4. WHAT OTHERS MAY SEE ABOUT YOU

When using the FriendWay App, you should assume that anything you submit on the App may be publicly-viewable and accessible, both by Users of the App and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Where you choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.

Your FriendWay profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook or Instagram – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be Users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your FriendWay account.

5. OUR POLICY TOWARDS AGE.

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use FriendWay.

FriendWay does not knowingly collect any information about or market to children, minors or anyone under the age of majority. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from FriendWay. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

6. SECURITY.

FriendWay has implemented appropriate security measures to protect and prevent the loss, misuse, unauthorised access or disclosure and alteration of the information under our control, including your personal data. We use reasonable security measures to safeguard the confidentiality of your personal information. Our technical experts at FriendWay work hard to ensure your secure use of our site.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!

If you ever think someone has had access to your password or Account, please follow the steps set out here. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

7. LINKING OTHER ACCOUNTS TO FRIENDWAY.

Using your social media details to sign in to FriendWay

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your FriendWay account and will be used to retrieve your FriendWay account.

When you sign in to our App using your Gmail account, we collect the following information with your permission:

• Basic Profile Information: This includes your name, profile picture, and email address. We use this information to create and manage your user account on our service.
• Email Address: We collect your email address to communicate with you, send you updates about our service, and for account recovery purposes.
• Authentication Tokens: We receive authentication tokens from Gmail to facilitate the login process without storing your Gmail password.

Please note, we do not have access to your Gmail password at any time. The login process is handled securely by Gmail, ensuring your password remains private.

We will then use this personal data to form your FriendWay account. If you remove the FriendWay app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your FriendWay account using your Facebook or Apple ID (you must delete your FriendWay account entirely for us to no longer have access to this data).

Linking social media accounts to your FriendWay account

You may link your FriendWay account with your Instagram or Facebook accounts. This allows you to share some information from those accounts directly to your FriendWay account (for example, username).

We only receive the limited information that Instagram/Facebook permits to be transferred (as detailed by Instagram/Facebook and agreed by you when you first connect your account from such platforms with your FriendWay account).

If you no longer want to link your FriendWay account to your Instagram or Facebook account, please visit the settings in your Instagram or Facebook account and follow the instructions to remove the FriendWay app access permissions. Please note that any information already added to your FriendWay account from those platforms will not be deleted unless you delete it within your FriendWay account as well.

8. YOUR CALIFORNIA PRIVACY RIGHTS

For Users who are California residents, you have the following rights (in addition to those listed at section 9 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at info.friendway@gmail.com.

From time to time, as part of a joint promotion with a third party, we may, if you participate in such a promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, Under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

9. YOUR RIGHTS.

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organisation is processing and why (this notice).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you want to exercise any of your rights listed above please email our Data Protection Officer at info.friendway@gmail.com. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office(opens in new window) (ICO), the UK supervisory authority for data protection issues. If you live in a country or territory located in the European Union (EU) or European Economic Area (EEA), you may also get in touch with your local Data Protection Regulator(opens in new window). If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.

10. DATA RETENTION AND DELETION.

We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law. Please see “Profile Verification Information” in Section 1, above.

When your Account is deleted, we make sure it is no longer viewable on the App. We begin the process of deleting your personal information from our systems right away.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

11. CHANGES TO THIS POLICY.

As FriendWay evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at https://friendway-privacy-policy.web.app/.  If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within FriendWay.

Effective date. This Privacy Policy was last updated on: 15th May 2024.