Privacy Policy

Last update: November 13th, 2023

I.       Introduction
FRVR is committed to protecting users' personal data and ensuring their privacy when using (theServiceThe present Privacy Policy (hereinafter, referred to asPrivacy PolicyorPolicyinforms you on how FRVR Limited processes data provided by you and generated while using the Service as well as your rights and how the law is applicable.

Your data will be processed according to the standards of the General Data Protection Regulation (EU) 2016/679 (hereinafterGDPRof 27 April 2016, on the protection of natural persons with regard to the processing of personal data.

II.      Purpose of this Privacy Policy
This Policy serves to inform our users (hereinafter referred to asUsersorYou) on how we collect, store, process, use, and manage the information You provide us when using the Service.
The scope of this Privacy Policy is limited to the information collected by FRVR Limited and does not apply to third-party websites.

III.     Controller and contact details
FRVR Limited, a Maltese limited liability company with VAT no. MT24548624 (hereinafter referred to asFRVR” “WeorUswith registered address in 61, St. Paul Street, Valletta, VLT 1212, Malta, acts as the data controller in the terms set out in this Privacy Policy.
If You have any questions about this Privacy Policy or any other matter regarding personal data, FRVR has appointed a Data Protection Officer for these and other matters so please contact Us by sending a letter to the address included in the previous paragraph or an email at

IV.      Definitions
For a better understanding of this Privacy Policy, We provide You with a list of definitions:
Personal data: any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, electronic identifiers, or email of that natural person;
Processing: the operation or set of operations carried out on personal data, whether by automated or non-automated procedures, such as the collection, registration, organization, structuring, conservation, adaptation or modification, recovery, consultation, use, dissemination by transmission, diffusion or any other form of availability, comparison or interconnection, limitation, erasure or destruction;
User or Data subject: the natural person who uses Our Service and who, for some reason, personal data is processed;
Data controller: the natural or legal person, the public authority, the agency or other body that, individually or in conjunction with others, determines the purposes and means of processing personal data. For the purposes of this Policy, FRVR is the personal data controller;
Data processor: natural or legal person, the public authority, agency, or other body that processes personal data on behalf and in accordance with the instructions of FRVR;
Personal data recipient: natural or legal person, public authority, agency or other body that receives personal data provided by FRVR; and
Supervisory Authority: means an independent public authority that is established by an EU Member State.

V.       General Principles applicable
Regarding general principles applicable to the processing of personal data, FRVR ensures that this data is:
Subject to lawful, fair, and transparent processing;
Collected for specific, explicit, and legitimate purposes, not being later processed in an incompatible manner with those purposes;
Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and updated whenever necessary, taking all appropriate measures so that the inaccurate data, taking into account the purposes for which it is processed, is erased or rectified;
Kept in a way that allows the identification of the User only for the period necessary for the purposes for which the data is processed; and
Processed in a way that guarantees datas safety, including protection against its unauthorized or unlawful processing and against its accidental loss, destruction, or damage, implementing appropriate technical and organizational measures.

VI.      Personal Data
FRVR´s primary objective in collecting User information is to provide and enhance the Service and to enable Users to easily enjoy the Service.
While using our Service, We may collect certain Personal Data that can be used to identify You.

FRVR collects two types of data on our users: passive and active.
Active sources data
We may collect data based on direct interactions you have with us such as Your account information, as well as:
Account information: When You create an account with us, We collect information associated with Your account, including Your first name, last name, account credentials (e.g., Your username and email), and profile picture;
User Content: When You use Our Service, We collect Personal Information that may be included in the input, information, file uploads, or feedback that you provide to our Service;
Both account information and user content data are collected with the objective of improving our Service performance and providing features to our Users that benefit their User experience.
The lawfulness of the data processing is the legitimate interest as regards the collection of Service data to improve the Service by identifying possible errors or bugs.
The retention period of this data is of 1 year after the collection of the data any identifier is anonymized.
Communication Information: If You communicate with Us, We collect Your name, contact information, and the contents of any messages You send. The lawfulness of the data processing is the User consent and We may process identification data solely for the purpose of answering Your request. Typically, these requests include customer support and information on purchases of Service products.
The lawfulness for the data processing is the User consent and the retention period is 6 months after request completion.

The above data used to identify and track an individual might be stored by FRVR according to GDPR.
If non-personal information is collected, for an activity that also requires personal information, FRVR may combine your non-personal information with your personal information in an attempt to provide you with a better user experience, improve the quality and value of the Services, and analyze how the Service is used.

Passive sources data
Passive collection is data collected when Users navigate and use the Service. This data contains the following information:
Log Data: Information that Your browser automatically sends when you use our Services. Log data includes Your Internet Protocol address, browser type and version, user agent string any cookies based on consent, the date and time of your request, and how you interact with Our Service;
Usage Data: We may also collect information that Your browser sends whenever You visit Our Service, such as the types of content that You view or engage with, the features You use, and the actions You take, as well as Your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and Your computer connection.
Device Information: name of the device, operating system, device identifiers, and browser You are using. Information collected may depend on the type of device You use and its settings.
Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

The passive sources data is collected with the objective of improving our Service performance and providing features to our Users that benefit their User experience.
The lawfulness of the data processing is the legitimate interest as regards the collection of Service data to improve the Service by identifying possible errors or bugs.
The retention period of this data is 1 year after the collection of the data any identifier is anonymized.

This data does not contain any personally identifying information.

VII.     Disclosure of personal information

(I) Third-party platforms
When you use or connect to the Services by or through a third-party Platform, such as Google or Linkedin, you may consent that FRVR assesses and/or collects information from that platform, if applicable, as informed by such services. Those third parties may also collect information from your interaction with Our services. Such collection is managed by that third party, according to the terms of the agreement and your privacy settings with the third-party Platform.

(II) Consent & data communication with third parties
Users will be asked to give consent to FRVR to access, collect, and process their personal data and share it with third parties, for instance, for advertisement purposes.
In all other cases, the information You provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely to provide You with and improve the Service.
In case, for any lawful reason where consent is not needed, we communicate Your data with third parties, We will do it in an aggregated and anonymized form, which is not possible for these third parties to identify you as a person.

(III) International Transfers
FRVR does not transfer personal data to organizations outside the European Economic Area.

(IV) Other Disclosure of Your Personal Information
You understand and agree that We may be required to disclose any personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to avoid liability, to comply with legal processes, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public. Note that FRVR is not required to question or contest the validity of any search warrant, subpoena, or other similar governmental request that FRVR may receive.
Additionally, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information may be transferred to FRVRs successor or assignee, if permitted by and done in accordance with applicable law.

VIII.    Children
The Service may be used by minors over 13 years old, submitted with permission given by parents or guardians. In case you are a minor and use the Services, you ensure and warrant to us that you have obtained the necessary permission from your parent or guardian.
Most of our Users Service data is processed anonymously, thus we do not gear our Services towards children under the age of 13 and we do not knowingly collect Personal data from children under the age of 13. If We know that a child under 13 has provided Us with Personal Data, We will delete such information from our files as quickly as possible.
If You are under 18 and do not understand the content presented in this Policy, please ask for support from Your legal representatives - parents or legal guardians.

IX. Links to other websites
The Service may contain links to other websites not operated or controlled by FRVR, including social media services (“Third Party SitesThe information that You share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links We do not imply that We endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

X. Security and Retention
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. In particular, emails sent to or from us may not be secure. Therefore, You should take special care in deciding what information You send to Us via the Service or email. In addition, We are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
Well retain Your Personal Information for only as long as we need in order to provide our Service to You, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with Our legal obligations. How long We retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, Our purpose for processing the information, and any legal requirements.
We have implemented technical and organizational measures designed to secure Your personal information from accidental loss and unauthorized access, use, alteration, or disclosure. However, We cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending Us personal information through these mediums.
Among others, We have implemented the following technical and organizational measures:
Data access controlby default only limited people from FRVR who process data have access to the systems and applications where the data is residing;
Monitoring of accessessystematic control of who is accessing our systems and applications;
Data encryption and pseudonymization;
Strong compliance frameworkongoing confidentiality, integrity, availability, and resilience of the processing systems and services;
Login credentialsall people from FRVR who access personal data must log in through personal credentials in order to process data;
Database segregationsegregation of databases based on data requirements and processing activities; and
We will keep working on providing more protection for your Personal data by improving or implementing additional technical and organizational measures thus do bear in mind these might alter.
XI. Cookies
FRVR uses cookies or similar technologies on its websites and games.For more information, please read our Cookie Policy.
XII. User´s Rights
Regarding personal data processing, Our users dispose of rights that may be exercised. Note that if a third-party data controller, such as an advertising partner or a payment processor, is responsible for the information, We will take reasonable steps to inform them of Your request, but We recommend You contact them directly in accordance with their privacy policies to ensure your rights are executed lawfully. You have the following rights:
Right of Access: the right to obtain confirmation that Personal data concerning the User is or is not subject to processing and, if so, the right to access such personal data and certain information.
Right of Rectification: the right to rectify inaccurate personal data concerning the User or to request incomplete personal data to be completed.
Right to Erasure: right to obtain the erasure of personal data, without undue delay as long as there are no valid grounds for its conservation, such as cases in which data has to be kept in order to comply with a legal obligation or because legal proceedings are underway.
Right to restriction of processing: right to request a limitation on the processing of personal data, in the form of suspension of processing or limitation of the scope of processing to certain categories of data or processing purposes, in accordance with article 18 of the GDPR.
Right of Portability: right to receive personal data that concerns the User in a structured, common use, and automatic reading format and/or the right to transmit this data to another controller.
Right of Objection: the right of the User to object to the processing of data at any time, as long as there are no legitimate reasons for such processing that prevail over the interests, rights, and freedoms of the users, or for the purposes of declaration, exercise or defense of a right in a judicial proceeding.
You may revoke Your consent, in processing activities dependent on obtaining consent, without such revocation invalidating the processing of the data while the consent was in force. This shall be applied as long as the user provides the needed information.
You may also exercise your right of erasure or restriction of processing as regards advertisement by resetting your mobile advertising identifier (IDFA or GAID) or activatingLimit Ad Trackingin your devices settings in order to make previously collected data nonlinkable to you or your device anymore and limit further data collection.
Finally, we inform you have an additional right to lodge a