Frenly Protocol Privacy & Cookie Policy
1. INTRODUCTION
Who are we?
We are Halza Limited S.A., a company incorporated and registered in the Republic of Panama with registration number (Folio) 155732306 and registered office at Vía España, Torre Banco Delta, Piso 6, Ciudad de Panamá, República de Panamá. Where we decide the means or purpose of processing your personal data, we are the data "controller."
What's this policy about?
This policy explains how we process your personal data as a data controller when you:
- are a "User" of our website (https://getfrenly.com) any of its respective subdomains, and any other website or app of ours that links to this privacy policy (together, the "Services");
- interact with our business as a supplier (a "Supplier"); and
- apply for a role in our business (as a "Prospective Employee").
We update this policy from time to time so please check back in.
Contact us (if you have questions about this policy or to exercise your rights)
Write to us at: support@getfrenly.com with any questions about our personal data processing.
If you are in the European Union, European Economic Area, or United Kingdom and we cannot resolve your issue, you can get in touch with the supervisory authority in your country. If you are located elsewhere, you may contact the relevant data protection authority in your jurisdiction.
What are your rights?
You have the following rights in respect of personal data, although these rights may be limited in some circumstances (we will let you know if they are limited when you contact us to exercise them):
- Ask us to send a copy of your data to you or someone else
- Ask us to restrict, stop processing, or delete your data
- Object to our processing of your data
- Object to use of your personal data for direct marketing
- Ask us to correct inaccuracies
If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.
Is there anything else to note?
Please note that when you use the Services, you are interacting with Ethereum and other EVM blockchains, which provide transparency into your transactions. Frenly does not control and is not responsible for any information you make public on the Ethereum or other blockchains by taking actions through the Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and are not responsible for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly if you have any questions.
2. YOUR PERSONAL DATA AND HOW WE USE IT
Enquiry Data
Your data: Information we receive when you get in touch, including:
- Name
- Email address
- Location data (inferred from your IP address if you use customer support chat)
- Other personal data you send to us as part of enquiries
How long we keep it: 7 years from when our relationship with you ends.
How we use it: We process this information to respond to your support and other enquiries.
Legal basis: We may process this data in accordance with the terms of our contract with you (where we need this information to provide Services to you) or to take steps you request prior to entering into a contract. We also use this to pursue our legitimate interests, including: (a) our interest in responding to enquiries to ensure smooth operation of our business and services; and (b) to understand our customers and improve our Services, by taking onboard your feedback.
More information: You may be required to provide us with certain information for us to respond to your enquiries.
Sources: We collect this information from you when you send it to us.
Recipients: We may use third-party customer relationship management tools to process this data. We will also disclose personal data as required by applicable law or a binding court order.
Stream/Distribution Information
Your data: We use the following data to display details of active and historic token distributions on our website:
- Wallet addresses (of sender and recipient)
- Status of distributions (e.g., tokens distributed, daily limits, and the status of the distribution)
How long we keep it: We do not store this data which is simply fetched and displayed through our website as and when requested.
How we use it: Our website may allow visitors to view the status of token distributions, in which case the website will display publicly available information about distributions available on the relevant blockchain.
Legal basis: We process this data to pursue our legitimate interest in providing visitors to our website the ability to view the status of distributions more easily through a graphical user interface, rather than querying the blockchain directly.
Sources & Recipients: We collect this from the public blockchain, using APIs provided by blockchain infrastructure providers. We will also disclose personal data as required by applicable law or a binding court order.
Sanction Screening
Your data: We use the following data to check whether wallets interacting with our platform might be subject to sanctions:
- Wallet address
How long we keep it: We do not store your wallet address after comparing it against sanction lists.
How we use it: In some cases, if you use our Services, we may compare your wallet address against sanction lists.
Legal basis: We may process this data to comply with our legal obligations from time to time. We also use this to pursue our legitimate interests, including our interest in restricting the use of our Services by those who are subject to sanctions.
Sources & Recipients: We use third-party compliance services to carry out sanction checks. We will also disclose personal data as required by applicable law or a binding court order.
User Analytics
Your data: Data about how you interact with our Services, including:
Log and Usage Data: Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).
How long we keep it: It depends on the service concerned (please see the information below). Where we have a choice we will retain personal data for a maximum of 26 months, but we may retain aggregated statistics generated from that data which are anonymous.
How we use it: We use cookies, similar technologies and other software to collect analytics data about users of our Services, to understand how people use them, where they come from, which devices and operating systems they use, and how they interact with our Services, along with logs of errors which may occur in providing our Services, to help improve and maintain our Services, and to identify usage trends. See section 3 below for more details.
Legal basis: We process analytics data if you have given your consent.
More information: You can opt out of allowing us to collect this information either by refusing consent to our use of cookies and similar technologies, or (in the case of Location Data) by disabling your Location setting on your device.
Sources & Recipients: We use various analytics and monitoring service providers to process some of this data. We will also disclose personal data as required by applicable law or a binding court order.
Supplier Information
Your data: Data collected and processed in order to manage our relationships with suppliers to our business, including:
- Name
- Job title
- Employer
- Phone number
- Email address
Legal basis: We may process this data to comply with our legal obligations from time to time. We also use this data to pursue our legitimate interests in running our business and managing our relationship with our suppliers.
Sources: We collect this information from you when you send it to us. We may also collect this information from places where it is publicly available.
Recipients: We may provide this information to other suppliers if needed in the context of your work with us. We will also disclose personal data as required by applicable law or a binding court order.
Prospective Employees
Your data: Data collected and processed about individuals who may apply for a role in our business, including:
- Name
- Job title
- Employer
- Phone number
- Email address
- CV/resume and employment history
- References
Legal basis: We may process this data to comply with our legal obligations from time to time. We may request your consent in order to process some of this data, in particular any data which is "special category data" such as data relating to your health. We also use this data to pursue our legitimate interests in our recruitment activities.
Sources: We collect this information from you when you send it to us. We may also collect information about you from places where you have made it publicly available.
Recipients: We will disclose personal data as required by applicable law or a binding court order.
Data Retention: Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorized access, and legal requirements.
3. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they are essential for our sites, apps or services.
Most browsers allow control over cookies. For more information on managing cookies in your browser:
Other settings to disable certain similar technologies:
- Windows Advertising ID
- iOS and Mac OS Ad Tracking
- Your browser's "Do Not Track" settings
| Cookie/Technology | Duration | Purpose | Third Party Access |
|---|---|---|---|
| Essential Cookies | Session to 12 months | These cookies are necessary for the Services to function properly, including authentication, security, and basic functionality | None |
| Analytics Cookies | 12-26 months | To help us understand how you use our Services, such as how often and which features are used, so we can improve our Services | Third-party analytics providers |
| Performance Monitoring | 30-90 days | To monitor errors and performance issues to maintain and improve the Services | Third-party monitoring services |
4. TRANSFERS AND DISCLOSURE
International Transfers
Your data may be stored and processed in various jurisdictions. When we transfer personal data internationally, we ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws. This may include:
- Using standard contractual clauses approved by relevant authorities
- Ensuring the recipient country has adequate data protection laws
- Obtaining your explicit consent where required
For more information, including regarding the specific safeguards used to protect data which is transferred internationally, contact us using the details at the start of this policy.
Disclosure
Other than as set out above, we may disclose your personal data:
- Where required by law, government, competent authorities, or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
- With members of our corporate group, our suppliers, and subcontractors, as necessary for the purposes set out in this policy.
- If involved in an investment, merger, acquisition, or sale of our organization or assets, personal data we hold may be shared based on the legitimate interests of us, our shareholders, customers, and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.
5. AUTOMATED DECISION MAKING
We do not use automated decision making in relation to any of your personal data.
6. SECURITY
We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. However, please note that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security.
7. CHILDREN'S PRIVACY
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected personal data from a child, please contact us immediately so we can take appropriate action.
8. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. When we make changes, we will update the "Last updated" date at the top of this policy. We encourage you to review this policy periodically to stay informed about how we protect your data.
9. CONTACT US
If you have any questions about this Privacy Policy or our data practices, please contact us at:
Email: support@getfrenly.com
Address: Halza Limited S.A., Vía España, Torre Banco Delta, Piso 6, Ciudad de Panamá, República de Panamá
Your privacy matters to us. By using the Frenly Protocol Services, you acknowledge that you have read and understood this Privacy Policy.