Privacy Policy

General information

Framey Technologies Limited, with registered office at 2/ F, 156 Wellington Street, Central, Hong Kong, registered with Companies Registry under number 2920925, duly represented by Robert-Costel PREOTEASA, as Director (hereinafter referred to as “Framey”, “subscribed” or “us”).

Framey respects your right to privacy and is dedicated to the protection of your personal data and the proper use of this data.

From personal data protection view, Framey is a Controller regarding the personal data we process about you.

Before submitting any information within the Framey mobile application (“FrameyApp”), please read this Privacy Notice carefully.

We reserve the right to change or periodically update this Privacy Notice at any time in our sole discretion. You will be notified in advance of these changes and / or updates, please read carefully and make sure you understand.

Personal Data we process about you

As this term is used in this Privacy Notice, personal data means any information about you when using the FrameyApp, based on which you can be identified directly or indirectly, through other indicators:

  • Username;
  • Phone number;
  • E-mail address;
  • Short description about you;
  • Credentials of your device: IP, location, date, hour, type of device;
  • Photos of you;
  • Connection credentials of your device: IP, location, time, device type
  • Information that may contain your personal data, which you share with other users. 

As explicitly is stated in the Terms of Use of the application and for which you are directly responsible, for the security of your personal data, it is important to NOT post/ comment on FrameyApp information with your personal data, which may affect you!  

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you in advance and you have given us explicit consent.

 

For what purpose we use your personal data?

The processing of your personal data that you voluntarily transmit upon registration and use of the application is mainly done to ensure the functionality of the application.

However, please note that there are situations in which we may legally process this data without your consent:

  • to fulfil our contractual obligations to you, or
  • to protect a legitimate interest that we or a third party may have, unless your fundamental interests or rights and freedoms prevail.

The data we collect will be used exclusively for the purpose for which you transmitted it to us, and this purpose is clearly communicated to you at the time of collection or in this Privacy Notice.

Where your personal data is stored?

Your personal data will be processed and stored by us and our service providers throughout the world in the Cloud Services.

Each of our service providers who process and store your personal data has an obligation to keep it protected and secured, in accordance with applicable industry standards and regardless of whether less stringent legal provisions apply in their jurisdiction.

Moreover, most service providers acting as persons authorized to process personal data on behalf of Framey are registered in the US-EU Privacy Shield, which is a framework for the transatlantic exchange of personal data for commercial purposes between the EU and the United States, approved by the EU through the EU-US Privacy Shield Decision adopted on 12 July 2016. The US-EU Privacy Shield provides for a self-certification mechanism whereby US-based companies commit to the principles of confidentiality provided under the US-EU Privacy Shield, which is considered to be an adequate level of protection of personal data.

For how long do we store your personal data?

We assure you that your personal data will only be stored for a strictly necessary period of time, in accordance with the purpose for which it is collected. For information, we will retain your personal data:

– during the period in which we have the obligation to comply with the laws applicable to us;

– for the time necessary to provide your services and to fulfil our obligations to you;

– for a period of time provided for by the applicable limitation period – 3 years, in order to be able to respond to any potential complaints and requests and to protect our rights and any legitimate interests;

– the time it takes to answer your questions, provide guidance, and resolve issues related to our services;

– until such time as you exercise your right of deletion or your right to data portability under the conditions set out in the section on your rights, subsections D and F)

Upon expiration of the above deadlines, your personal data will be deleted. If, at any time, you wish to stop using your personal data to provide you with services, please contact us as described in the Your Rights section.

If your requests to delete your personal data violate our legal or regulatory obligations, or the data related to the request for deletion are necessary for the exercise or defence of our legal claims, we may not be able to honour your request.

Security of your personal data

Framey has implemented all necessary technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the personal data you share with us. These measures have been implemented to protect your data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability. Framey has a 24/7 network traffic monitoring system to detect signs of attacks or intrusions.

Your Rights

You will have, at any time, the following rights regarding your personal data processed by us (“Rights“):

(A) The right to basic information.

(B) Right of access.

(C) The right of rectification.

(D) Right of erasure (“right to be forgotten”).

(E) The right to limit processing.

(F) The right to data portability.

(G) Right of opposition.

(H) The right not to be subject to a decision based solely on automatic processing.

We will respect your rights of access, rectification, limitation, deletion and opposition, free of charge. We may charge a reasonable fee for repeated requests or requests that we consider to be manifestly unfounded or excessive, or for additional copies.

We will respond to you within 30 days of receiving a request from you regarding these rights. If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. If you do not meet this deadline, you can file a complaint with the competent Data Protection Authority and request legal remedies.

To exercise your Rights mentioned above, you can contact us at: [email protected]

For any questions or requests for clarification in connection with this Privacy Notice, we invite you to contact us at: [email protected]