News

Welcome to the web site operated by Friv B.V. (the “Company"), accessible at https://Friv.com. “Site" means web sites of the Company and its affiliates, including any web sites on which these terms and conditions of use are posted. The “Site" may include access to virtual environments, games and other content, as well as downloadable software or applications for use on personal computers, tablets, mobile devices or phones. All users of the Site are subject to the following terms and conditions of use (these “Terms of Use").

Please read these Terms of Use carefully before accessing or using any part of this Site. By accessing or using this Site, you agree that you have read, understand and agree to be bound by these Terms of Use, as amended from time to time, as well as the Company Privacy Policy, which is hereby incorporated into these Terms of Use. If you do not wish to agree to these Terms of Use, do not access or use any part of this Site.

The Company may revise and update these Terms of Use at any time without notice by posting the amended terms to this Site. Your continued use of the Site means that you accept and agree to the revised Terms of Use. If you disagree with the Terms of Use (as amended from time to time) or are dissatisfied with this Site, your sole and exclusive remedy is to discontinue using this Site. It is your responsibility to regularly check the Site to determine if there have been changes to these Terms of Use and to review such changes.

USE OF THE SITE

You agree to use the Site only for lawful purposes:

(a) Specifically you agree not to do any of the following: (1) upload to or transmit on the Site any defamatory, indecent, obscene, harassing, violent or otherwise objectionable material, or any material that is, or may be, protected by copyright, without permission from the copyright owner; (2) use the Site to violate the legal rights (including the rights of publicity and privacy) of others or to violate the laws of any jurisdiction; (3) intercept or attempt to intercept electronic mail not intended for you; (4) misrepresent an affiliation with any person or organization; (5) upload to or transmit on the Site any advertisements or solicitations of business; (6) restrict or inhibit use of the Site by others; (7) upload or otherwise transmit files that contain a virus or corrupted data; (8) collect information about others (including e-mail addresses) without their consent; (9) download a file or software or include in a message any software, files or links that you know, or have reason to believe, cannot be distributed legally over the Site or that you have a contractual obligation to keep confidential (notwithstanding its availability on the Site); (10) post “spam," transmit chain letters or engage in other similar activities; (11) solicit, provide or exchange any personal information, including but not limited to user names or passwords; (12) “stalk," “phish," abuse or harass another user, or attempt to do any of the foregoing; or (13) engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Site, or which, as determined by the Company, may harm the Company or users of the Site or expose them to liability. Without limiting any of the foregoing, you also agree to abide by any code of conduct and policies applicable to the Site or any service available on the Site.

(b) Any content and/or opinions uploaded, expressed or submitted to a message board, blog, chatroom or any other publicly available section of the Site (including password-protected areas), and all articles and responses to questions, other than the content provided by the Company, are solely the opinions and responsibility of the person or entity submitting them and do not necessarily reflect the opinions of the Company. You understand and acknowledge that you are responsible for whatever content you submit, and you, not the Company, have full responsibility for such content, including its legality, reliability and appropriateness. By uploading or otherwise transmitting material to any area of the Site, you warrant that the material is your own or is in the public domain or otherwise free of proprietary or other restrictions and that you have the right to post it to the Site. You grant to the Company the royalty-free, irrevocable, perpetual, transferable and world-wide right and license to use all content you upload or otherwise transmit to the Site in any manner the Company chooses, including, but not limited, to copying, displaying, performing or publishing it in any format or media whatsoever, modifying it, incorporating it into other material or making a derivative work based on it.

(c) Except as expressly authorized by the Company in writing, you may not reproduce, sublicense, distribute, sell or exploit for any commercial purposes (i) any part of this Site or its content, (ii) access to this Site or (iii) use of this Site or of any services or materials available through this Site, including, without limitation, by leasing access to the Site (e.g., at a cyber café), gathering and selling virtual items, codes, pre-paid game cards, or virtual currency through the Site, or otherwise.

(d) The Company reserves the right, but does not assume any responsibility, to (1) remove any material posted on the Site which the Company, in its sole discretion, deems inconsistent with the foregoing commitments (including any material that the Company has reason to believe constitutes, or for which the Company has received notice of its constituting, a copyright infringement); (2) monitor and/or record communications between and among users on the Site; and (3) terminate any user’s access to all or part of the Site. However, the Company can neither review all material or communication before it is posted on the Site nor ensure prompt removal of objectionable material after it has been posted. Accordingly, the Company assumes no liability for any action or inaction regarding transmissions, communications or content provided by third parties. The Company reserves the right to take any action it deems necessary to protect the personal safety of users of this Site and the public; however, the Company has no liability or responsibility to anyone for performance or nonperformance of the activities described in this paragraph.

(e) Your failure to comply with the provisions of (a), (b) or (c) above may result in the termination of your access to the Site and may expose you to civil and/or criminal liability.

PRIVACY: PROTECTION OF PERSONAL INFORMATION

The Company’s use of your personal information and your responsibilities in connection with protecting your privacy are described in the Company Privacy Policy, which is incorporated by reference into these Terms of Use.

UPLOADS TO YOUR DEVICES

Please note that if you are using downloadable applications from the Company, updates to your device’s systems or firmware may render your use of the applications incompatible. The Company does not warrant that the Site or any Company applications will be compatible with any updates to, or prior versions of, your devices. The Company may, but is not obligated to, provide you with updates to the Site or applications that improve compatibility with updated mobile devices.

DATA CHARGES

To the extent that your use of the Site or any Company application requires, or permits utilization of, wireless, cellular data, or internet access, you are independently responsible for securing the necessary data access service. For example, with respect to your mobile devices, the provider of your data plans may charge you data access fees in connection with your use of the Site or Company applications. You are solely responsible for all such charges payable to third parties.

COPYRIGHT RESTRICTIONS/USE OF CONTENT

The entire contents of this Site (including all information, text, displays, images and audio and any software made available through or in connection with the Site) and the design, selection and arrangement thereof, are proprietary to the Company or its affiliates or licensors and are protected by United States and international laws regarding copyrights, trademarks, trade secrets and other proprietary rights. You are authorized only to use the content on the Site for personal use related to your role as a current or prospective user of the Site. You may not copy, modify, create derivative works of, publicly display or perform, republish, store, transmit or distribute any of the material on this site without the prior written consent of the Company, except to: (a) store copies of such materials temporarily in RAM, (b) store files that are automatically cached by your web browser for display enhancement purposes, and (c) print a reasonable number of pages of the Site; provided in each case that you do not alter or remove any copyright or other proprietary notices included in such materials. Neither the title nor any intellectual property rights to any information or material in this Site are transferred to you, but remain with the Company or the applicable owner of such content.

SOFTWARE AND DOWNLOADS If the Company offers downloads of, or access to, software on this Site and you download or otherwise access such software, the software (including any data or images incorporated in or generated by the software) is licensed to you. You do not receive title to this software and you may not distribute or use the software other than for the purpose of using the applicable feature or service of the Site as offered by the Company. You may not modify, adapt, reverse engineer, decompile, disassemble or otherwise attempt to discover the source code of such software. Except as expressly provided, you may not create any derivative works of the software or any services available on the Site. This license is revocable at any time without notice and with or without cause. You agree to destroy or return to the Company all copies of the software upon revocation of your license to the software and/or termination of your access to the Site. The software is subject to all restrictions on use, disclaimers of warranties and other provisions in these Terms of Use. In the event that the software is also subject to a separate end user license agreement, the terms of such end user license agreement shall control any conflict between those terms and these Terms of Use.

ACCESS AND INTERFERENCE

You agree that you will not (a) use any robot, spider or other automatic device, process or means to access the Site, (b) use any manual process to monitor or copy any of the material on this site or for any other unauthorized purpose without the prior written consent of the Company, (c) use any device, software or routine that interferes with the proper working of the Site, (d) attempt to interfere with the proper working of the Site, (e) take any action that imposes an unreasonable or disproportionately large load on the Company’s infrastructure, or (f) access, reload or “refresh" transactional pages, or make any other request to transactional servers, more than once during any three (3) second interval.

TRADEMARKS

The Company name and logos, and all related names, logos, product and service names, designs and slogans contained in the Site or any software provided or accessed in connection therewith are trademarks of the Company, its affiliates, licensors and/or contractors unless otherwise clearly specified in writing. You may not use such marks without the prior written permission of the Company. All other names, brands and marks are used for identification purposes only and may be the trademarks of their respective owners.

LIABILITY OF THE COMPANY AND ITS LICENSORS

The Company does not assume any liability for the materials, information and opinions provided on, or available through, the Site (the “Site Content"). Reliance on the Site Content is solely at your own risk. The Company disclaims any liability for injury or damages resulting from the use of any Site Content.

THE SITE IS PROVIDED “AS IS" AND “AS AVAILABLE," WITHOUT ANY WARRANTY OR GUARANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. THE COMPANY, ITS AFFILIATES AND SERVICE PROVIDERS ARE NEITHER RESPONSIBLE NOR LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE OR OTHER DAMAGES ARISING OUT OF OR RELATING IN ANY WAY TO THE SITE. THE COMPANY SHALL NOT BE HELD LIABLE UNDER THIS AGREEMENT OR OTHERWISE IN CONNECTION WITH THE SITE FOR AN AMOUNT MORE THAN $500.

INTERACTION WITH OTHER USERS

As a condition of access to the Site, you release the Company (and its shareholders, partners, affiliates, directors, officers, subsidiaries, employees, agents, suppliers, third party information providers, licensors, licensees, distributors and contractors) from claims, demand and damages (actual and consequential) of every kind and nature arising out of or in any way connected with any dispute you may have with any other user of the Site. The Company will have the right but not the obligation to resolve disputes between users relating to use of the Site, and to the extent that it elects to resolve such disputes, the Company will do so in good faith based on the general rules and standards of the Company and the Site. You release the Company (and its shareholders, partners, affiliates, directors, officers, subsidiaries, employees, agents, suppliers, third party information providers, licensors, licensees, distributors and contractors) from claims, demands and damages (actual and consequential) of every kind and nature arising out of or in any way connected with the Company’s resolution of such disputes.

INDEMNIFICATION

You agree to indemnify and hold harmless the Company and its shareholders, partners, affiliates, directors, officers, subsidiaries, employees, agents, suppliers, third party information providers, licensors, licensees, distributors, contractors and others involved in the Site or the delivery of products, services or information over the Site, from and against any and all liabilities, expenses, damages and costs, including reasonable attorney’s fees, arising from any violation by you of these Terms of Use or your use of the Site or any products, services or information obtained from the Site.

COMMENTS AND SUBMISSIONS

The Company welcomes your comments. All comments, suggestions or other information sent by you to the Company or its advertisers or business partners in response to solicitations on this Site will become the Company’s property and you agree that all intellectual property rights therein are transferred to the Company. For avoidance of doubt, the Company shall own any developments by the Company or on its behalf arising out of your comments, suggestions or other submissions. To the extent the Company does not own such materials, you grant and agree to grant the Company a non-exclusive, royalty-free license to utilize, create derivative works of, distribute and sublicense such materials for any purpose in connection with the Company’s web sites, products and services. You have no expectation of any review, compensation or consideration of any type for all submissions hereunder.

LINKS TO OTHER SITES

The Site contains links to other web sites on the Internet. The Company is not responsible for and does not endorse the content, products, services or practices of any third party web sites, including, without limitation, sites framed within the Site or third party advertisements, and does not make any representations regarding their quality, content, accuracy, or suitability for your viewing or use. Your use of third party web sites is at your own risk and subject to the terms and conditions of use for such web sites. In the event that you choose to purchase a product or service from a third party, the Company is not responsible for such products or services, as it is not party to such transaction and is not liable for any direct or indirect costs or damages arising out of any dispute between you and such third party. NEITHER THE COMPANY, ITS LICENSORS OR CONTRACTORS, MAKES ANY EXPRESS OR IMPLIED REPRESENTATIONS OR WARRANTIES REGARDING THE GOODS OR SERVICES OFFERED BY SUCH MERCHANT, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT OR COMPATIBILITY.

COPYRIGHT INFRINGEMENT AND OTHER INTELLECTUAL PROPERTY INFRINGEMENT

In accordance with the Digital Millennium Copyright Act (DMCA) and other applicable law, the Company may, in appropriate circumstances and in the Company’s sole discretion, terminate your access to this Site if it deems you to be a repeat infringer. The Company may also, in its sole discretion, limit your access to the Site and/or terminate your membership if you infringe any intellectual property rights of others, whether or not there is any repeat infringement.

Please contact our designated agent at [email protected] if you become aware of any content that may infringe the copyright of a third party or that you believe to be in violation of these Terms of Use.

Additionally, if you believe that any of the content on the Site violates your intellectual property rights, please contact us at  [email protected]

CHOICE OF LAW

These Terms of Use shall be governed in all respects by and construed in accordance with the laws of the State of Illinois, USA, without regard to its conflicts of law principles.

MISCELLANEOUS

These Terms of Use, as they may be amended from time to time, completely and exclusively state the agreement between you and the Company with respect to the Site, and no other terms that may have been communicated to you orally or in any other manner shall have any force or effect. Any cause of action you may have with respect to the Site must be commenced within one (1) year after the claim or cause of action arises or such claim or cause of action is barred.

You agree and acknowledge that your violation of any restrictions in these Terms of Use on the use of the Site, Site Content, or software or services available on or through the Site, or your use or disclosure of Confidential Information in a manner inconsistent with the provisions of these Terms of Use, may cause the Company irreparable damage for which remedies at law may be inadequate. You agree that, in the event of your unauthorized use of the Site, Site Content, software and services, or your unauthorized disclosure of Confidential Information, the Company will be entitled to injunctive relief, in addition to such other legal and equitable remedies that may be available. The Company’s licensors and contractors are express third party beneficiaries of any terms in these Terms of Use that are applicable to their products or services, including disclaimers of warranty and limitations of liability, and shall have the right to enforce directly against you all of your applicable representations, warranties, covenants, indemnifications and obligations under these Terms of Use.

If any part of these Terms of Use is unenforceable (including, without limitation, any part of the binding arbitration provision above), the unenforceable part shall be construed to reflect, as nearly as possible, the original intentions of the parties. The other provisions of these Terms of Use shall remain in full force and effect.

The terms related to protection of the Company’s intellectual property rights, disclaimer of warranties limitation of liability, choice of law and binding arbitration, indemnification obligations and any licenses granted by you to the Company shall survive any termination of these Terms of Use.

The Company’s failure to insist upon or enforce strict performance of any provision of these Terms of Use shall not constitute a waiver of the provision. Neither a course of dealing or conduct between you and the Company nor any trade practices shall be deemed to modify these Terms of Use.

This Privacy Policy was last updated on December 17 2019.

Friv is committed to protecting the privacy of all visitors who use our site and applications, including older users above the age of 13 (“General Users") and younger users under the age of 13 (“Children Users"), together the “Users".

This privacy policy (“Privacy Policy" or “Policy") is designed to provide transparency into Friv’s privacy practices and principles for information that we collect from General Users through our Friv web platform, mobile applications, our Friv Publishing services, and other general-audience sites and applications (“Friv General Site"), as well as information that we may collect from Children Users through our separate Friv site (“Friv Kids Site").

The Friv General Site and Friv Kids Site (together, the “Friv Site") are owned and operated by Friv B.V. (referred to in this Policy as “Friv", “we", “our", or “us"). Friv B.V. (“Friv") is an entity incorporated under the laws of the Netherlands.

By using the Friv General Site, you agree to observe and be bound by this Privacy Policy and you consent to the processing, collection, use, and disclosure of your information and data in accordance with the terms of this Privacy Policy. Please do not use the Friv Site if you do not agree to this Privacy Policy. If you are a parent or legal guardian, by allowing your child(ren) to use the Friv Kids Site, you are agreeing to the terms of this Privacy Policy on your child’s behalf.

To view our privacy practices specific to the Friv Kids Site and Children Users, please click here. If you have any questions concerning this Privacy Policy, please contact us at [email protected].

1. General information

All features on the Friv Site are available without the need for registration by Users. No personal data (such as email addresses and phone numbers) are requested from users. Friv may collect certain electronic data (such as the User’s IP address, cookies or device ID).

When a User clicks to leave the Friv Kids Site, Friv may try to inform the User that they are leaving the Friv Kids Site and that this Privacy Policy will no longer apply. When a User provides personal data on any third party website or application, the processing of such personal data will be governed by any privacy statement applicable to that site/application. In any event, Friv shall not act as the Data Controller or the Processor of such personal data.

2. Data collection and its purposes

Our servers automatically recognize visitors’ domain names and IP addresses (the number assigned to computers on the Internet). The Friv Site may gather anonymous “traffic data" that does not personally identify you, but that data may be helpful for marketing purposes or for improving the services we offer.

When your computer or mobile device contacts our web servers (for example, when you visit the Friv Site), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate the Friv Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, and referrer data that identifies the web page visited prior and subsequent to visiting our Site.

Traffic information may also be shared with business partners and advertisers on an aggregate and anonymous basis. More information about sharing information will follow in part 7.

In addition, Advertisers on the Friv General Site might receive information gathered by cookies for targeted advertising purposes. Further information regarding the use of cookies can be found below.

3. Data Retention

Friv may retain users’ data for the following purposes:

To develop new features and improve the Friv Site;

To support subsequent customer service inquiries;

To improve the safety and security of the Friv Site; or

Comply with our legal obligations.

We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected.

4. Third party games

This Privacy Policy does not apply to the processing of personal data by data controllers other than Friv, such as providers of third party games available on the Friv Site. The relevant provider of such a third party game is responsible for ensuring that any processing of personal data by them in the context of a game complies with applicable data protection laws.

Generally, Friv does not permit third party content providers to collect personal data about Users. However, if any personal data will be collected by a third party content provider, Friv will contractually require that the processing of personal data by them in the context of a game complies with applicable data protection laws.

5. Cookies

Like many websites and applications, this Friv Site makes use of “cookies" which are saved on the user’s computer. In addition, third party networks serving advertisements on the Friv Site (the “Advertisers") might use cookies. Cookies are a way of remembering who you are. A cookie is a small text file that is stored on your computer’s hard drive or stored temporarily in your computer’s memory. There are two kinds of cookies: those that are “session" oriented and those that are “persistent". Session cookies delete from your computer when you close your browser. Persistent cookies retain information for later use tomorrow, next week, next month, or whenever they are set to expire.

Friv and its Advertisers may use cookies, or similar technologies to enhance and personalize your experience on the Friv General Site, including the following:

to operate and improve offerings on the Friv Site;

to help authenticate you when you are on the Friv Site;

to remember your preferences;

to present and help measure and research the effectiveness of Friv’s offerings;

to customize the content provided to you through the Friv Site; and,

to show targeted ads.

For information on how cookies are used on the Friv Kids Site, please see the below Children Users section.

Users can refuse the saving of cookies or delete them by adjusting the browser settings on his or her computer. To learn more on how to adjust the settings of your internet browser, we recommend the user visit the website of the browser’s vendor.

The user can also decide to remove installed cookies. Users can do so in the following manners:

Internet Explorer

Delete existing Tracking Technologies through the “Internet Options" sub-option of the “Tools" menu option of your browser or otherwise as directed by your browser’s support feature. Disable future Tracking Technologies by using the same browser controls. Additional information on disabling most Tracking Technologies may be available through your browser’s support feature. (See the “help" section of your browser for more information.)

Google Chrome

Delete existing Tracking Technologies through the “Clear Browsing Data…" sub-option of the “Tools" menu option of your browser or otherwise as directed by your browser’s support feature. Disable future Tracking Technologies by using the same browser controls. Additional information on disabling most Tracking Technologies may be available through your browser’s support feature. (See the “help" section of your browser for more information.)

Mozilla Firefox

Delete existing Tracking Technologies through the “Clear Recent History…" sub-option of the “History" menu option of your browser or otherwise as directed by your browser’s support feature. Disable future Tracking Technologies by using the same browser controls. Additional information on disabling most Tracking Technologies may be available through your browser’s support feature. (See the “help" section of your browser for more information.)

You may be able to have the device you use to access the Friv Site warn you each time a cookie or most other Tracking Technologies is being set (other than Flash cookies), or you can choose to turn off such warnings. This is done through your browser on the device you use to access the Website. Additional information on warnings and removal of warnings may be available through your browser’s support feature.

Please note that deleting, rejecting, disabling or turning off Tracking Technologies through the above options will not remove Flash cookies. For more information about Flash cookies and how to remove them from your computer, please visit Adobe’s website.

Please be aware that certain areas and features of the Friv Site can only be accessed in conjunction with Tracking Technologies, and that disabling Tracking Technologies might prevent you from accessing such content.

If you have any questions concerning cookies, please contact us at [email protected].

6. Links to third party websites

The Friv General Site knowingly links out to the following third party websites. The names of these third party websites link to their privacy policy.

YouTube

Facebook

Instagram

Whatsapp

Twitter

Kik

Some of the third party games published on the Friv General Site and Friv Kids Site do link out to third party websites. Friv uses technology and people to monitor these links for inappropriate content but it does not have full control over the third party games on the Friv Site.

7. Sharing information

Friv may share your persistent identifiers with third parties such as business partners under the following circumstances:

Security: We may release information about our Users, including IP address, when legally required to do so, at the request of governmental authorities conducting an investigation or to verify or enforce compliance with the policies governing the Friv Site and applicable laws. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of Friv, or any of our respective business partners, customers or others.

Aggregate Information: We may disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited this Friv Site during a specific time period or played a specific game on this Website.

Advertising: We may share technical information such as IP address or device ID with our advertising partners. For advertising on the Friv General Site, this information may be used to serve behaviorally targeted ads or profiling. For advertising on the Friv Kids Site, this information will only be shared for the purposes of serving contextual advertising and capping the frequency of ads.

8. International Data Transfers

Friv may work with third parties that are based outside of the European Economic Area (EEA), and may transfer data about you to the countries in which these parties reside. Whenever we share personal data originating in the EU with an entity outside of the EEA, we will do so on the basis of the EU standard contractual clauses, with your consent, or because such transfer is necessary performance of a contract.

If you have any questions about our policy regarding international data transfers, please contact us at [email protected]

9. Children Users

We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. This is why we created a separate age-appropriate experience for Children Users through the Friv Kids Site, or through an age-gate in certain games on the Friv General Site: in order to comply with the legislation, you could be presented to an age screen when starting the game. When presented with this age screen, it is important that you state the correct age. Based on your age information and your device settings, Friv does not process personal data of children under the minimum age limit (Children Users) that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement.

The Children Users’ experience of games with an age-gate on the Friv General Site, and the Friv Kids Site supports and complies with the Children’s Online Privacy Protection Act (“COPPA"). The Children Users’ experience of games with an age-gate on the Friv General Site and the Friv Kids site will not request any personal information from Children Users. There is no registration required for the Friv Kids Site and any advertising shown on the Friv Kids Site, or in the the Children Users’ experience of games with an age-gate on the Friv General Site, is age-appropriate. The Friv Kids Site and the Children Users’ experience of games with an age-gate on the Friv General Site will not show behaviorally targeted ads or allow third parties to track the activity of Children Users for that purpose.

The Friv Kids Site and the the Children Users’ experience of games with an age-gate on the Friv General Site may collect and use IP addresses and other persistent identifiers, including cookies, from Children Users, but only for purposes of supporting our internal operations, such as to help us:

Identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data

Maintain or analyze the functioning of the Friv Kids Site

Perform network communications

Authenticate users of, or personalize the content on, the Friv Kids Site

Serve contextual advertising on the Friv Kids Site and cap the frequency of advertising

We have separated our platform into a few sections. Friv Kids was created for our youngest audience and is fully COPPA compliant. If you are a Child User, you should only use the Friv Kids Site and only with the permission of a parent or legal guardian. On Friv, you’ll find games that are intended at users that are over 13. Friv is not targeted towards children under the age of 13 and it will not knowingly collect personal information from children under 13.

To learn more about COPPA, please reference this simple one-page informational guide from the kidSAFE Seal Program: https://www.kidsafeseal.com/knowaboutcoppa.html.

10. Lawful Bases for Processing Personal Data

If you are an individual in the European Union (EU), we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:

It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Service, and increasing the security of the Service and network infrastructure;

You have consented to this collection and processing for a specific purpose;

It is necessary to fulfil our contractual obligations; or

It is necessary to comply with a legal obligation.

Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in section 11 addressing Individual Rights. Some examples of our legitimate interests and the data being processed include:

Network and information security (IP address, user/device ID)

Customer Support and fraud prevention (email address)

Improving our products and services (activity logs)

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in section 12 regarding the Contacts for Individual Rights Requests.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected].

11. Individual Rights

Friv makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated. We may request more information to confirm your identity before acting on any request.

Review and update your data: You have the right to access and update any personal data that we have collected. To review or update this data, please submit a request using the contact information at the end of this section.

Delete your data: You also hold the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section.

After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.

Restrict Processing: You have the right to restrict how we process your personal data in certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting we delete all of your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.

Data Portability: You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data.

Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.

If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.

12. Contact for Individual Rights Requests

Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.

Email: [email protected]

If you are an EU citizen or reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

13. Revisions to this Privacy Policy

We may change this privacy policy from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. If we update this policy, changes will be reflected on this page and we will update the “last updated" date above. We will obtain prior parental consent for any changes we make if those changes affect Children Users in a way that requires parental consent under COPPA.

14. Contact information

If you have any questions concerning this Privacy Policy, or data collection in particular, please contact us at [email protected]