Privacy Policy

Operated by Novum Studio  |  Last Updated: 8 April 2026

1

Who We Are

Fr. App is a social video platform operated by Novum Studio. Novum Studio is the data controller responsible for your personal data. We are committed to complying with the UK GDPR and EU GDPR.

If you have any questions about this Privacy Policy or how we handle your data, please contact us at contact@thefr.app.

2

Data We Collect

2.1 Information You Provide

Account data: username, password, name, date of birth, phone number, email address, profile picture, gender

Profile content: bio, links, and other information you add to your profile

User Content: videos, comments, and other content you post

Communications: messages you send to us or other users

Financial information: PayPal email for withdrawals (we do not store card details)

2.2 Information We Collect Automatically

Device data: device type, operating system, unique device identifiers

Usage data: how you interact with the App, features used, time spent

Log data: IP address, access times, pages viewed, app crashes

Cookies: small data files stored on your device (see Section 7)

2.3 Information from Third Parties

PayPal (transaction confirmations)

Apple App Store / Google Play (purchase verification)

Referral tracking data

3

How We Use Your Data

3.1 Contractual Necessity

We process your data where necessary to perform our contract with you, including: account management, Diamond and Credit Score systems, withdrawal processing, content interaction, referral tracking, and subscription management.

3.2 Legitimate Interests

We process your data based on our legitimate interests, including: fraud detection and prevention, platform integrity, service improvements, analytics, and content personalisation.

3.3 Legal Compliance

We may process your data where necessary to comply with legal obligations.

3.4 Consent

Where we rely on consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

4

Who We Share Your Data With

PayPal: for processing withdrawals

Apple / Google: for in-app purchase verification

Infrastructure providers: hosting, storage, and CDN services

Legal compliance: law enforcement or regulatory bodies where required by law

Business transfers: in the event of a merger, acquisition, or sale

We do not sell your personal data to third parties.

5

International Data Transfers

Your data may be transferred to and processed in countries outside the EEA and UK. Where such transfers occur, we ensure appropriate safeguards are in place, including the use of Standard Contractual Clauses approved by the European Commission.

6

How Long We Keep Your Data

Account data: duration of active account + 2 years

Financial records: 7 years (legal requirement)

Usage / log data: 12 months

Support communications: 2 years

After the applicable retention period, your data is securely deleted or anonymised.

7

Cookies & Tracking Technologies

We use the following types of cookies:

Strictly necessary: required for the App to function properly

Performance / analytics: help us understand how you use the App

Preference: remember your settings and choices

We do not use targeted advertising cookies. You can control cookies via your device or browser settings.

8

Your Rights

Under data protection law, you have the following rights:

Access: request a copy of your personal data

Rectification: request correction of inaccurate data

Erasure: request deletion of your data

Restriction: request restriction of processing

Portability: request transfer of your data to another service

Objection: object to processing based on legitimate interests

Withdraw consent: where processing is based on consent

To exercise any of these rights, email contact@thefr.app. We will respond within 30 days.

8.1 Account Deletion & Content

Upon account deletion, your profile will be deleted or anonymised. However, content already unlocked by other users cannot be retroactively deleted from their devices.

8.2 Withdrawing Consent

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

8.3 Complaints

You have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO) at www.ico.org.uk. EU residents may contact their local data protection authority.

9

Children’s Privacy

Fr. App is not intended for children under the age of 13. Users aged 13–17 should obtain parental consent before using the App. Providing a false date of birth constitutes a breach of our Terms.

10

Security

We implement appropriate technical and organisational measures to protect your personal data. However, no system is completely secure. In the event of a data breach, we will notify affected users and the relevant supervisory authority as required by law.

11

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via in-app notification or email. We encourage you to review this policy periodically.

12

Contact Us

Postal: Novum Studio, England, United Kingdom

We aim to respond to all enquiries within 5 business days.

© 2026 Novum Studio. All rights reserved. Governed by the laws of England and Wales.

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