Privacy Policy

Last updated: March 23, 2023

Friendly Inc (“we” or “Friendly”), which is an affiliate of Sensor Tower Inc, (“Sensor Tower”), is honored to provide users with high quality, privacy friendly apps, which lets them take control of their data while enhancing their online experiences, whether it be on social media, streaming and or e-commerce.

This privacy policy (“Privacy Policy”) covers all of our mobile applications and websites including:

These websites and apps are collectively referred to as the “App” in this Privacy Policy.

The purpose of this Privacy Policy is to provide you with a clear understanding of what personal information we have access to when you use the App, as well as what personal information may be collected when you allow us to collect usage data, how your personal information is used, and the choices you have to control the collection and/or use of your personal information. We are committed to communicating transparently, providing security, and protecting the privacy of data on our systems.

Contact Information

If you have any questions, comments, or concerns about your personal information, this Privacy Policy, your privacy, or any of our privacy practices, please contact our Data Protection Officer by email at [email protected] or by mailing correspondence to Data Protection Officer at Sensor Tower, Inc., 2261 Market Street #4331, San Francisco, CA 94114.

Overview

This Privacy Policy explains how we collect, store, use, transfer and share your personal information in connection with the App, which may be available for download from the Google Play (TM) store or the App Store (R).

We reserve the right to update this Privacy Policy to reflect changes in and to keep you informed about our privacy practices. Please periodically review the App or the relevant store page for the latest information on our privacy practices.

If we make any changes, we will notify you by contacting you through the App, by posting a notice on the App, by posting a notice on our Google Play(TM) store or App Store ® page for the App, by posting a notice on our webpage(s), or by some combination of these methods. If you continue to use the App after the Privacy Policy has been updated, this continued use will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to the Privacy Policy.

If you do not accept the terms of the Privacy Policy, please discontinue using the App immediately.

Personal Information We Collect About You

Our App never collects or otherwise extracts your name, email, username, handle, phone number, or any of your other personal identifiers that you may use to identify yourself.

When you install the App, a randomly generated unique identifier (“Generic ID”) is used to distinguish your installation of the App from installations of the App by other users. In association with the Generic ID, we may receive the following additional information depending on which App you are using:

General Information:

Ad-related Information:

Order Information:

This personal information (the “Collected Data”) is de-identified upon collection using the Generic ID associated with the installation of the App. If you uninstall the App, any data that was collected becomes permanently anonymized.

Upon receiving any Collected Data, our policy is to delete your IP address from our logs within hours of receipt, unless an error is being debugged, in which case it is deleted upon resolution of the error. When stored, the Collected Data is pseudonymized using your Generic ID. If you uninstall the App, any Collected Data is permanently disassociated with that installation of the App and is at that point anonymized and cannot be used to re-identify you.

Special Category or Sensitive Personal Data

We never receive or process any of your sensitive personal information, such information regarding your sexual orientation, ethnicity, religious affiliation, refugee status, health, or finances.

Customer Support Information

Please note that the following exception to the above may apply when reporting an issue with the App or providing email feedback, as you may provide information by which you may be personally identifiable, such as your name and email address. We do not store this information in association with the personal information we may collect through the App.

Other Personal Information

When you use the App, it may also use technology to automatically collect:

How We Use Your Personal Information

Basis for Processing

We may process your personal information for the purposes described in this Privacy Policy, with your consent; when we have assessed it is necessary for the purposes of the legitimate interests pursued by us or a third party to whom it may be necessary to disclose information; or to comply with a legal obligation. If you have questions about these legal bases you can contact our Data Protection Officer.

Purposes of Processing

We may use your personal information for the following purposes:

Data Minimization and Purpose Limitation

We will not process your personal information in a way that is incompatible with the purposes for which it has been collected or collect any personal information that is not needed for these purposes.

No Sale of Personal Information

We do not and will never sell your personal information to advertising platforms, data brokers, or information resellers. We will also never sell your personal information as may be defined by applicable laws.

Use of Aggregated Information

We may aggregate anonymized technical information (Anonymized Information) from the Collected Data of the users of the App. We may use the Anonymized Information to develop, generate and validate the data and insights about app ecosystems that we provide on our website at sensortower.com and pathmatics.com. We may share Anonymized Information with our service providers that perform services on our behalf to help us provide, understand, or improve the App. For example, we may use service providers or other partners to help host our services and databases, perform analyses or research, send communications on our behalf, or measure the effectiveness of our advertising. Service providers can only use the Anonymized Information shared with them for the limited purpose under which it was shared, and cannot ever sell the Anonymized Information or use the Anonymized Information to personally identify you.

Use of Contact Information

In situations where you consensually provide us with contact information for the sole purpose of communicating with us, we may use your information to respond to your communications and send you information you request.

Sharing of your Personal Information

We may share or disclose your personal information in the following circumstances:

We may share or disclose Anonymized Information and information that does not identify any individual without restriction.

Retention of your personal information

When you use the App

The personal information we collect from you, as described above, is de-identified when collected and is retained for as long as needed to accomplish the purposes provided in this Privacy Policy. At any time, you can request that we erase any personal information that we have collected as outlined in the “Your Rights” section of this Privacy Policy.

When you delete the App

If you delete the App from your device, your Generic ID is permanently disassociated with that instance of the App and any of your personal information will become Anonymized Information. You should be aware that we may retain any such Anonymized Information after you have deleted the App. We reserve the right to use the Anonymized Information after you have deleted the App.

Your Rights

With us, you have rights and control over your personal information regardless of the country you live in. Many of these important rights are afforded by Europe's and the UK's General Data Protection Act (GDPR), which include:

How to exercise your privacy rights

Contact our Data Protection Officer using the contact information provided above to exercise any of your privacy rights. We commit to grant them within 30 days after receipt or less.

If you reside in Europe or the UK, you can also contact VeraSafe, which has been appointed as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to our Data Protection Officer, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland

Formalities to exercise your privacy rights

Please keep in mind that in the case of a vague request we may engage the individual in a dialogue so as to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.

We might also require you to prove your identity in some cases. This is made to ensure that no rights of third parties are violated by your request.

Other Items

Notification requirements. We commit to notify you, when it is needed under the law, within a reasonable period of time and your data protection authority within the timeframe specified in applicable law about data breaches related to your personal information.

Data Protection Authorities. Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with applicable law.

The California Consumer Privacy Act

If you are a California resident, then Under the California Consumer Privacy Act (‘CCPA’’), you have certain rights regarding the personal information that we may have collected about you. The following sections disclose the “what,” “how,” and “why” behind any personal information we collect about you, who we share it with, and what your rights are over your personal information.

Your Rights under CCPA

Similar to the GDPR, the consumer rights you may have under the CCPA include the right to have us:

You may read more about your California privacy rights at: https://cppa.ca.gov/

Submitting a Request, Question, or Feedback

If you would like to exercise any of your rights, or if you have any questions or would like to provide feedback on this Privacy Policy or our privacy practices, please email us using the following information and our privacy team will examine your request, question, or feedback and respond to you as quickly as possible.

Data Protection Officer

[email protected]

Categories of Personal Information We Collect

As summarized in detail in the Collected Data section above, we collect:

The basis for the collection of personal information and the manner in which personal information is used is outlined elsewhere in this document.

Sharing or Sale of Your Personal Information

We may share your personal information under the circumstances outlined in the Sharing of your Personal Information section above.

We do not sell your personal information. Aggregated Anonymized Information, which cannot be re-identified and does not identify you or any individual person, is exempted under the CCPA (e.g., see Section 1798.145. Exemptions) and is provided for sale as summarized in the Use of Aggregated Information section above.

“Do Not Track” Requests

We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.

Security of your personal information

We maintain reasonable and appropriate safeguards to protect all collected personal information against loss, misuse, theft, unauthorized access, disclosure, alteration, or destruction. While we strive to protect your information and privacy, no data transmission or storage can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of information you disclose or transmit to us and cannot be responsible for the theft, destruction, misuse, unauthorized access, alteration, or inadvertent disclosure of your information.

If we become aware of a security systems breach, we will attempt to inform you by posting a notice, publishing a press release, notifying you via the App, or other appropriate means, and will take appropriate steps to remedy the breach in compliance with any applicable laws and as specified in this Privacy Policy.

Children’s Privacy

General age limitation. We are committed to protecting child privacy. The App is not intended for children and we do not intentionally or knowingly collect information, personal or otherwise, about individuals under the age of 18, much less children under 13 years old. If you are aware of anyone under 18 using the App, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the App.

Age limitation for EU residents. To the extent prohibited by applicable law, we do not allow use of the App by EU residents younger than 18 years old. If you are aware of anyone younger than 18 using the App, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the App.

Storage and International Transfers

We are based in the United States of America (U.S.) and the personal information we collect is governed by U.S. law. Please be advised that the laws in the U.S. and the laws of other countries may not offer the same protections as the law of your jurisdiction, and may be deemed inadequate relative to your country’s data protection law.

Further, you agree that we may store and process your information through third-party or affiliate hosting services in the United States, European Economic Area (“EEA”), and other international jurisdictions. As a result, we, our affiliates, subsidiaries, or agents may securely transfer your information to a jurisdiction with different data protection laws than your jurisdiction. By using the Services, you explicitly and unambiguously consent to the transfer of your information outside of your own country for the purposes described in this Privacy Policy.

Third-party Data Processors

We use data processors that perform particular operations with your personal information for us.

Data processors (or just processors) are companies that help us, the Data Controller, run the App, support our communication with you or perform other App-related activities. They may process certain personal information on our behalf to accomplish the goals related to the App functions and associated activities. Data processors act only in accordance with instructions and process only the personal information that we instruct them to process. We are liable for any acts or omissions of our data processors and engage with them under data processing agreements to the extent required by applicable law.

The following is a list of our main data processors:

TypeProcessorData ProcessedPurpose
Infrastructure and securityAWS (Amazon Web Services)App usage information.Storage of usage information while using the App.
AnalyticsFirebaseAnalytics-related information: app version, anonymous demographics, events describing how the app is used.Analyze usage patterns within the app to optimize flows and retention.

Third-party Links

This Privacy Policy may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.