Friday: AI Keyboard Privacy Policy 

Version: 1.04

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the service or applications and tells you about your privacy rights and how the law protects you.

I. INTRODUCTION.

Sekterra GmbH (“we,” “us,” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use the “Friday: AI Keyboard” software application for mobile devices (the “App,” “our App”).

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social status.

Our Privacy policy applies to all users and others who access the App (“Users”).

For the purposes of the GDPR, we are the data controller unless otherwise stated.

We have appointed a Data Protection Officer to assist Us with compliance with applicable privacy regulations.

Data Protection Officer: 

Legal Nodes Ltd

Address: 90a High Street Berkhamsted, Hertfordshire, England, HP4 2 BL

Contact person’s details: dpo.sekterra@legalnodes.com

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Functional information and information that you submit

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide the complete functionality of the App and perform the requested services.

• Activity Information directly related to your use of the App. After you allow access to your keyboard, we may see your messages as you type them. However, we never collect, store or use this information.
• Account Information which may include your account credentials (such as email address) and user settings (e.g., selected keyboard languages, auto-correction, feedback on keypress). You may use your Google or Apple account to register and log in to our App. 
• Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, or support form. We collect, store, and process it by our cloud storage provider (DigitalOcean, Inc.). We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.

Google API

The App’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information That Is Processed Automatically 

On the basis of your permission, we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular, to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity. You can withdraw your permission at any time - please check the opt-out options in Section VIII below.

We may process some information about your device and your user behavior on the ground of our legitimate interest. This information falls within the categories of data described above in the Subsection “Information That Is Processed Automatically”; it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information to improve our App and give our users the best experience.

• Device Details. When you use a mobile device (tablet/phone/smartwatch) to access our App, some details about your device are reported, including “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by third parties.

What data can be processed:

• Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume, and battery, device memory usage.
• Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, and browser.
• Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, and time zone.
• Device identifiers: Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices, user identifiers.
• Information about the applications. Name, API key (identifier for application), version, and properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
• Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App and how you interact with the App.
• Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record of that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
• In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).

Payment Information

Our e-commerce provider (Apple) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use the functional information, information that you submit and information that is processed automatically to provide you with all requested services. The lawful basis for this processing activity is the performance of the contract between us and the Users.  

(b) To improve, test and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App. We rely on our legitimate interests to carry out this processing activity. 

(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. We may rely on our legitimate interests to carry out this processing activity or your consent.

(d) To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us. We may rely on our legitimate interests to carry out this processing activity or your consent.

(e) To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use. We may rely on our legitimate interests to carry out this processing activity.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.

Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such third party. 

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may share your personal data with third-party AI models, such as OpenAI, to process the text input you provide for text generation, checking spelling and grammar, translation, and personalization.

We may engage the following third-party service providers or our affiliates in order to provide us with necessary infrastructure for delivery and improvement of our services:

Amplitude Inc. – Analytics service provider U.S.A.

https://amplitude.com/privacy

AppsFlyer Inc. – Analytics service provider U.S.A.

https://www.appsflyer.com/legal/services-privacy-policy/

Facebook (Meta Platforms, Inc.) – Analytics / ad management service provider U.S.A.

https://www.facebook.com/privacy/explanation

Firebase (Google LLC) – Analytics service provider U.S.A. https://policies.google.com/privacy

https://firebase.google.com/support/privacy

OpenAI, L.L.C. – AI services provider U.S.A. We use OpenAI’s AI engine for text generation. For more information on what type of information OpenAI collects and how they process data, please visit the OpenAI’s Privacy & Terms web page: https://beta.openai.com/policies/privacy-policy

RevenueCat Inc. Analytics service provider U.S.A. https://www.revenuecat.com/privacy/

In case you want to learn more about these services and their privacy options (including opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

• as required by law;
• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union, UK, Switzerland or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. For example, when we transfer your data to a third party (e.g., a service provider) outside of the EU, UK or Switzerland, we will ensure to implement special contractual commitments (such as the Standard Contractual Clauses) with them to ensure that there are sufficient safeguards in place to protect your data.  To find out more about the appropriate safeguards for international transfers, please use the contact details below.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. You can do so within the settings of the App. 

However, some data such as payment information may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.
• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

If you are located in the European Union, UK or Switzerland, you may address our representative when you have questions on privacy issues: support@safecalls.live.

VIII. HOW TO OPT OUT

Opt-out of marketing tracking

If you don’t want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:

• Choose option "Limit Ad Tracking" on your iOS device in Settings/ Privacy/ Advertising, please find additional information here: 
• https://support.apple.com/en-us/HT202074;

Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

If you don’t want third-party service providers to use your precise location data, or street-level location information about you please follow the instructions below:

• iOS 11 or later: turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable App and set the “Share My Location” status to “Never”. Please see additional information here: https://support.apple.com/en-us/HT203033.

IX. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

X. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XI. HOW TO CONTACT US

If you have any questions about this Privacy Policy, You can contact us:

• By email: support@safecalls.live
• By mail: Baarerstrasse 25, 6300 Zug Switzerland

You can also contact our Data Protection Officer at: dpo.sekterra@legalnodes.com