PRIVACY POLICY

Last updated: August 30, 2024

Welcome to Fred, a social media management platform that helps you plan, create, and schedule your posts across various social media channels. Fred is owned and operated by Christian Vondru, from Portugal (“we”, “us”, “our”, or “Fred”).

We respect your privacy and are committed to protecting your personal data. This privacy policy (“Policy”) explains how we collect, use, and share your personal data when you access or use our website www.superfred.com, our mobile application app.superfred.com, and any other products or services we provide (collectively, the “Platform”), and what rights and choices you have regarding your personal data.

Please read this Policy carefully before using the Platform. By using the Platform, you agree to the collection, use, and sharing of your personal data as described in this Policy. If you do not agree to this Policy, you must not use the Platform.

This Policy may change from time to time, and we will notify you of any material changes by posting the updated Policy on the Platform and/or sending you an email. Your continued use of the Platform after any changes constitutes your acceptance of the new Policy.

  1. What personal data do we collect and why?

Personal data means any information that can be used to identify you as an individual, either directly or indirectly. We collect and use different types of personal data depending on how you interact with us and the Platform. We collect and use your personal data for the following purposes:

  • To provide and improve the Platform and its features. We collect and use your personal data to enable you to access and use the Platform and its features, such as connecting your social media accounts, uploading and scheduling posts, and managing your social media presence. We also use your personal data to monitor and analyze the performance, functionality, and usage of the Platform and its features, and to maintain, update, and enhance the Platform and its features.
  • To communicate and respond to your inquiries. We collect and use your personal data to communicate with you regarding the Platform and its features, such as sending you notifications, alerts, confirmations, and updates. We also use your personal data to respond to your questions, comments, feedback, or requests for customer support.
  • To personalize and optimize your experience. We collect and use your personal data to personalize and optimize your experience on the Platform, such as remembering your preferences and settings, providing you with relevant content and recommendations, and offering you tailored features and services.
  • To market and promote the Platform and its features. We collect and use your personal data to market and promote the Platform and its features, such as sending you newsletters, offers, promotions, and surveys. We also use your personal data to measure and improve the effectiveness of our marketing and promotional campaigns.
  • To protect and secure the Platform and its users. We collect and use your personal data to protect and secure the Platform and its users, such as detecting, preventing, and resolving any fraud, abuse, security, or technical issues. We also use your personal data to enforce our terms and conditions, policies, and legal rights, and to comply with any applicable laws, regulations, or requests from authorities.
  1. What types of personal data do we collect and why?

The types of personal data that we collect and use for the above purposes include:

  • Account information. When you register for an account on the Platform, we collect and use your name, email address, password, and any other information that you provide or update on your account profile.
  • Social media information. When you connect your social media accounts to the Platform, we collect and use your information from those accounts, such as your profile information, friends list, followers, contacts, messages, comments, likes, shares, and any other data that you authorize us to access, in accordance with the privacy settings that you have set in those accounts.
  • Content information. When you upload, store, share, or distribute content on or through the Platform, such as text, images, videos, audio, links, and other materials, we collect and use your content and any information associated with your content, such as the date, time, location, and metadata of your content.
  • Usage information. When you access or use the Platform or any of its features, we collect and use information about your usage, such as the date, time, duration, frequency, and type of your access or use, the features and functions that you use, the posts that you create, schedule, or publish, the social media platforms that you connect or integrate with, and any other actions that you take on or through the Platform.
  • Device and technical information. When you access or use the Platform or any of its features, we collect and use information about your device and technical specifications, such as your device type, model, operating system, browser, IP address, unique device identifiers, and other information that may identify your device or your online activity.
  1. How do we share and disclose your personal data?

We do not sell your personal data to any third parties. We only share and disclose your personal data with your consent or as necessary to provide and improve the Platform and its features, or to comply with any legal obligations or requests. We may share and disclose your personal data with the following categories of recipients:

  • Social media platforms. When you connect your social media accounts to the Platform, we share and disclose your personal data with those platforms, such as your profile information, friends list, followers, contacts, messages, comments, likes, shares, and any other data that you authorize us to access, in accordance with the privacy settings that you have set in those platforms. We also share and disclose your personal data with those platforms when we publish and update your content on those platforms on your behalf, subject to these Terms and the terms and conditions of those platforms.
  • Service providers. We may share and disclose your personal data with our service providers, such as payment processors, cloud hosting providers, analytics providers, email service providers, and other third-party vendors that we use to support the operation, maintenance, improvement, and promotion of the Platform and its features. We only share and disclose your personal data with our service providers to the extent necessary for them to perform their services for us, and we require them to protect your personal data and use it only in accordance with our instructions and this Policy.
  • Business partners. We may share and disclose your personal data with our business partners, such as affiliates, advertisers, sponsors, or other third parties that we collaborate with to offer you certain features, services, or promotions on the Platform or on their platforms. We will obtain your consent before sharing and disclosing your personal data with our business partners, and we will only share and disclose your personal data with our business partners that have agreed to protect your personal data and use it in accordance with this Policy and any other agreements that we may have with them.
  • Legal authorities. We may share and disclose your personal data with legal authorities, such as law enforcement, courts, regulators, or other government agencies, if we are required to do so by law or in response to a valid legal request, such as a subpoena, court order, or search warrant. We may also share and disclose your personal data with legal authorities if we believe that such action is necessary to: (a) comply with legal process; (b) enforce these Terms or this Policy; © protect our rights, property, or safety, or the rights, property, or safety of our users or the public; or (d) cooperate with an investigation or prevent or address fraud, abuse, security, or technical issues.
  1. How do we protect and secure your personal data?

We are committed to protecting and securing your personal data from unauthorized access, use, disclosure, alteration, or destruction. We implement appropriate technical and organizational measures to safeguard your personal data, such as encryption, firewalls, access controls, and security audits. However, you acknowledge and agree that no method of transmission over the Internet or method of electronic storage is 100% secure, and that we cannot guarantee the absolute security of your personal data. You are responsible for protecting your account and password, and for limiting access to your devices and browsers.

  1. How long do we retain your personal data?

We retain your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests. The retention period of your personal data may vary depending on the type and purpose of the data, and the applicable laws and regulations. When we no longer need your personal data, we will delete or anonymize it, or, if this is not possible, we will securely store your personal data and isolate it from any further processing until deletion is possible.

  1. What rights and choices do you have over your personal data?

You have certain rights and choices over your personal data, depending on the laws and regulations that apply to you. These rights and choices may include:

  • Access. You have the right to access and obtain a copy of your personal data that we hold, subject to certain exceptions and limitations.
  • Correction. You have the right to correct or update your personal data that we hold, if it is inaccurate or incomplete.
  • Deletion. You have the right to request the deletion of your personal data that we hold, subject to certain exceptions and limitations.
  • Restriction. You have the right to request the restriction of the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Objection. You have the right to object to the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Portability. You have the right to request the transfer of your personal data that we hold to another service provider, subject to certain exceptions and limitations.
  • Withdrawal of consent. You have the right to withdraw your consent to the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Complaint. You have the right to lodge a complaint with a supervisory authority, if you believe that we have violated your data protection rights.

To exercise any of your rights and choices over your personal data, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform. We will respond to your request as soon as possible, and in any case within one month, unless we need more time to process your request, in which case we will inform you of the reason and the expected time frame. We may ask you to verify your identity and provide additional information or documentation to fulfill your request. We may also charge a reasonable fee or refuse to act on your request, if your request is manifestly unfounded, excessive, or repetitive.

  1. How do we use cookies and other tracking technologies?

Please refer to the Cookie Policy for more information on this section.

  1. How do we obtain your consent?

We obtain your consent to collect, use, and share your personal data in various ways, depending on the context and the purpose of the data processing. We may obtain your consent through:

  • Explicit consent. We may ask you to provide your explicit consent to collect, use, and share your personal data for specific purposes, such as sending you marketing and promotional communications, or sharing your personal data with our business partners. You can provide your explicit consent by clicking a button, checking a box, or performing a similar action that indicates your agreement. You can withdraw your explicit consent at any time by following the instructions on the Platform or contacting us at support@superfred.com.
  • Implicit consent. We may infer your implicit consent to collect, use, and share your personal data for certain purposes, based on your actions or behavior, such as accessing or using the Platform or any of its features, or connecting your social media accounts to the Platform. You can withdraw your implicit consent at any time by changing your settings on the Platform or on your device, or by deleting your account.
  • Legal consent. We may collect, use, and share your personal data without your consent, if we are required or permitted to do so by law, or if we have a legitimate interest that outweighs your privacy rights, such as protecting and securing the Platform and its users, or complying with any legal obligations or requests.

We will always inform you of the purpose and the legal basis of the data processing, and respect your rights and choices regarding your personal data.

  1. How do we handle children’s data?

The Platform is not intended for children under the age of 16, and we do not knowingly collect, use, or share any personal data from children under the age of 16. If we become aware that we have collected personal data from a child under the age of 16, we will delete such data as soon as possible, unless we are required or permitted to retain it by law. If you are a parent or guardian of a child under the age of 16, and you believe that your child has provided us with personal data without your consent, please contact us at support@superfred.com and we will take appropriate steps to delete such data and address your concerns.

  1. How do we transfer your personal data across borders?

We are based in Portugal, but we may transfer your personal data to other countries or regions that have different data protection laws and standards than your country or region of residence. For example, we may transfer your personal data to our service providers, business partners, or legal authorities that are located outside of your country or region of residence. We will only transfer your personal data across borders if we have a valid legal basis to do so, and if we ensure that your personal data is protected in accordance with this Policy and applicable laws and regulations. We will use appropriate safeguards, such as contractual clauses, to ensure the lawful and secure transfer of your personal data across borders.

  1. How do we respond to “Do Not Track” signals?

Some browsers and devices have a “Do Not Track” feature that lets you indicate that you do not want your online activity to be tracked. We do not currently respond to “Do Not Track” signals, as there is no uniform standard or consensus on how to interpret or implement them. However, we respect your rights and choices regarding your personal data, and you can always change your settings on the Platform or on your device, or delete your account, to limit or stop the collection and use of your personal data.

  1. Third-Parties.
  • Stripe

Fred utilizes Stripe for processing payments through the platform. Stripe collects certain personal information necessary for payment processing, including your name, billing address, credit card information, and email address. This information is stored securely by Stripe and is only used for the purpose of processing payments.

  • YouTube

Fred utilizes YouTube and uses YouTube API Services in order to allow you to post videos to your YouTube channels via our app and to be able to view your YouTube channel statistics in Fred.
By using Fred, you acknowledge that we collect, access, and store certain user information, including data provided through YouTube API Services. This information may include, but is not limited to, user activity data, preferences, and interactions within the app.
In compliance with privacy standards, Fred references and adheres to the Google Privacy Policy (http://www.google.com/policies/privacy), which you can review for more information on data handling practices.
You can revoke Fred’s access to your data at any time via the Google security settings page (https://security.google.com/settings/security/permissions). For any questions or complaints regarding our privacy practices, you can contact the Fred support team (support@superfred.com).

For more information on how Stripe collects and uses your personal data, please refer to their privacy policy: https://stripe.com/privacy

  • Google and Google Analytics

Fred utilizes Google Analytics to collect and analyze website traffic data. This data helps us understand how users are interacting with the platform and allows us to improve its functionality and user experience. The data collected by Google Analytics includes:

    • Website traffic data: This includes information such as the number of visitors, the pages they visit, the length of their visit, and the sources of their traffic.
    • Device information: This includes information such as the type of device used, the operating system, and the browser version.
    • Location information: This includes information such as the country, city, and region of the visitor.
    • Demographic information: This includes information such as the age and gender of the visitor.
    • OpenAI

Fred utilizes OpenAI technology to enable users to automatically generate texts for their social media posts. In the course of providing this service, certain data is shared with OpenAI’s AI models. This includes the text input provided by users and associated metadata necessary for generating the desired content.

To ensure transparency and maintain control over personal data, Fred clearly informs its users both in the privacy policy and within the user interface about the specific data that is shared with OpenAI. Use of this feature is entirely voluntary, and users must provide explicit consent before any data is shared. Importantly, Fred can be fully used without utilizing the OpenAI feature.

    • API

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

Google Analytics uses cookies and other tracking technologies to collect this data. You can learn more about how Google collects and uses data in its privacy policy: https://policies.google.com/privacy?hl=en-US

You can also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on: https://support.google.com/analytics/answer/181881?hl=en

Limited Use Requirements

Your privacy policy and use of Google user data obtained via Restricted and Sensitive Scopes must comply with the Limited Use Policy.

To attest your compliance with the Limited Use Policy, we suggest adding a disclosure that meets the following requirements:

  1. Easily visible to all users.
  2. Under 500 characters.
  3. Clearly calls out that the app complies with the Google API Services User Data Policy, including the Limited Use requirements.
  4. Contains a link to the Google API Services User Data Policy so that it’s easily accessible to all users.
  5. Example disclosure: “(App’s) use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.”

Note that apps distributed on Google Play are also subject to the Google Play Developer Distribution Agreement.

You can also find more information in the Limited Use Requirements section.

Once the disclosure is added to your app, please provide us with the URL or confirmation that you will not be adding a disclosure.

User Consent For AI Apps

Google is committed to protecting the privacy of its users, and this includes ensuring that users have control over how their data is used. To uphold this commitment, we require any app that shares data with external parties or builds databases to provide its services meet the following additional requirements

  • Clearly describes what data your app shares with third-party tools ( such as AI models) in the app’s privacy policy or user-interface.
  • Clearly demonstrate how your app acquires explicit user consent to share data with third-party tools (such as AI models)

Important Note:

By using Fred, you consent to the collection and use of your personal data by Stripe and Google Analytics as described in their respective privacy policies.

  1. How do we update this Policy?

We may update this Policy from time to time, to reflect changes in our data practices, the Platform and its features, or the applicable laws and regulations. We will notify you of any material changes by posting the updated Policy on the Platform and/or sending you an email. The date of the last update will be indicated at the top of this Policy. Your continued use of the Platform after any updates constitutes your acceptance of the new Policy. If you do not agree to the updated Policy, you must stop using the Platform and delete your account.

  1. How do we comply with the GDPR?

The General Data Protection Regulation (GDPR) is a data protection law that applies to individuals in the European Union (EU) and the European Economic Area (EEA). The GDPR grants individuals certain rights and choices over their personal data, and imposes certain obligations and responsibilities on data controllers and data processors.

We are a data controller with respect to the personal data that we collect and use on the Platform, and we are a data processor with respect to the personal data that we process on behalf of our users who are data controllers. We comply with the GDPR by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to access, correct, delete, restrict, object, port, withdraw consent, and complain.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within one month.
  • Cooperating with the supervisory authorities and complying with their decisions and guidance.

If you are an individual in the EU or the EEA, and you have any questions or concerns about our compliance with the GDPR, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. How do we comply with the CCPA?

The California Consumer Privacy Act (CCPA) is a data protection law that applies to individuals in California. The CCPA grants individuals certain rights and choices over their personal data, and imposes certain obligations and responsibilities on businesses that collect, use, or sell personal data.

We are a business under the CCPA, and we comply with the CCPA by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to know, access, delete, opt-out, and non-discrimination.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within 45 days.
  • Cooperating with the Attorney General and complying with their decisions and guidance.

If you are an individual in California, and you have any questions or concerns about our compliance with the CCPA, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. How do we comply with other data protection laws and regulations?

In addition to the GDPR and the CCPA, we may also comply with other data protection laws and regulations that apply to us or our users, such as the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Data Protection Act 2018 (DPA) in the UK, the Lei Geral de Proteção de Dados (LGPD) in Brazil, and any other applicable laws and regulations. We comply with these laws and regulations by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to access, correct, delete, restrict, object, port, withdraw consent, and complain.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within the time frame specified by the applicable law or regulation.
  • Cooperating with the relevant authorities and complying with their decisions and guidance.

If you have any questions or concerns about our compliance with any data protection laws or regulations that apply to you or your country or region of residence, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. How can you contact us?

If you have any questions, comments, or requests regarding this Policy or your personal data, please contact us at:

Christian Vondru

Email: support@superfred.com

We will use reasonable efforts to respond to your inquiries as soon as possible, and in any case within one month, unless we need more time to process your request, in which case we will inform you of the reason and the expected time frame. We may ask you to verify your identity and provide additional information or documentation to fulfill your request. We may also charge a reasonable fee or refuse to act on your request, if your request is manifestly unfounded, excessive, or repetitive.

PRIVACY POLICY

Last updated: December 12, 2023

Welcome to Fred, a social media management platform that helps you plan, create, and schedule your posts across various social media channels. Fred is owned and operated by Christian Vondru, from Portugal (“we”, “us”, “our”, or “Fred”).

We respect your privacy and are committed to protecting your personal data. This privacy policy (“Policy”) explains how we collect, use, and share your personal data when you access or use our website www.superfred.com, our mobile application app.superfred.com, and any other products or services we provide (collectively, the “Platform”), and what rights and choices you have regarding your personal data.

Please read this Policy carefully before using the Platform. By using the Platform, you agree to the collection, use, and sharing of your personal data as described in this Policy. If you do not agree to this Policy, you must not use the Platform.

This Policy may change from time to time, and we will notify you of any material changes by posting the updated Policy on the Platform and/or sending you an email. Your continued use of the Platform after any changes constitutes your acceptance of the new Policy.

  1. What personal data do we collect and why?

Personal data means any information that can be used to identify you as an individual, either directly or indirectly. We collect and use different types of personal data depending on how you interact with us and the Platform. We collect and use your personal data for the following purposes:

  • To provide and improve the Platform and its features. We collect and use your personal data to enable you to access and use the Platform and its features, such as connecting your social media accounts, uploading and scheduling posts, and managing your social media presence. We also use your personal data to monitor and analyze the performance, functionality, and usage of the Platform and its features, and to maintain, update, and enhance the Platform and its features.
  • To communicate and respond to your inquiries. We collect and use your personal data to communicate with you regarding the Platform and its features, such as sending you notifications, alerts, confirmations, and updates. We also use your personal data to respond to your questions, comments, feedback, or requests for customer support.
  • To personalize and optimize your experience. We collect and use your personal data to personalize and optimize your experience on the Platform, such as remembering your preferences and settings, providing you with relevant content and recommendations, and offering you tailored features and services.
  • To market and promote the Platform and its features. We collect and use your personal data to market and promote the Platform and its features, such as sending you newsletters, offers, promotions, and surveys. We also use your personal data to measure and improve the effectiveness of our marketing and promotional campaigns.
  • To protect and secure the Platform and its users. We collect and use your personal data to protect and secure the Platform and its users, such as detecting, preventing, and resolving any fraud, abuse, security, or technical issues. We also use your personal data to enforce our terms and conditions, policies, and legal rights, and to comply with any applicable laws, regulations, or requests from authorities.
  1. What types of personal data do we collect and why?

The types of personal data that we collect and use for the above purposes include:

  • Account information. When you register for an account on the Platform, we collect and use your name, email address, password, and any other information that you provide or update on your account profile.
  • Social media information. When you connect your social media accounts to the Platform, we collect and use your information from those accounts, such as your profile information, friends list, followers, contacts, messages, comments, likes, shares, and any other data that you authorize us to access, in accordance with the privacy settings that you have set in those accounts.
  • Content information. When you upload, store, share, or distribute content on or through the Platform, such as text, images, videos, audio, links, and other materials, we collect and use your content and any information associated with your content, such as the date, time, location, and metadata of your content.
  • Usage information. When you access or use the Platform or any of its features, we collect and use information about your usage, such as the date, time, duration, frequency, and type of your access or use, the features and functions that you use, the posts that you create, schedule, or publish, the social media platforms that you connect or integrate with, and any other actions that you take on or through the Platform.
  • Device and technical information. When you access or use the Platform or any of its features, we collect and use information about your device and technical specifications, such as your device type, model, operating system, browser, IP address, unique device identifiers, and other information that may identify your device or your online activity.
  1. How do we share and disclose your personal data?

We do not sell your personal data to any third parties. We only share and disclose your personal data with your consent or as necessary to provide and improve the Platform and its features, or to comply with any legal obligations or requests. We may share and disclose your personal data with the following categories of recipients:

  • Social media platforms. When you connect your social media accounts to the Platform, we share and disclose your personal data with those platforms, such as your profile information, friends list, followers, contacts, messages, comments, likes, shares, and any other data that you authorize us to access, in accordance with the privacy settings that you have set in those platforms. We also share and disclose your personal data with those platforms when we publish and update your content on those platforms on your behalf, subject to these Terms and the terms and conditions of those platforms.
  • Service providers. We may share and disclose your personal data with our service providers, such as payment processors, cloud hosting providers, analytics providers, email service providers, and other third-party vendors that we use to support the operation, maintenance, improvement, and promotion of the Platform and its features. We only share and disclose your personal data with our service providers to the extent necessary for them to perform their services for us, and we require them to protect your personal data and use it only in accordance with our instructions and this Policy.
  • Business partners. We may share and disclose your personal data with our business partners, such as affiliates, advertisers, sponsors, or other third parties that we collaborate with to offer you certain features, services, or promotions on the Platform or on their platforms. We will obtain your consent before sharing and disclosing your personal data with our business partners, and we will only share and disclose your personal data with our business partners that have agreed to protect your personal data and use it in accordance with this Policy and any other agreements that we may have with them.
  • Legal authorities. We may share and disclose your personal data with legal authorities, such as law enforcement, courts, regulators, or other government agencies, if we are required to do so by law or in response to a valid legal request, such as a subpoena, court order, or search warrant. We may also share and disclose your personal data with legal authorities if we believe that such action is necessary to: (a) comply with legal process; (b) enforce these Terms or this Policy; © protect our rights, property, or safety, or the rights, property, or safety of our users or the public; or (d) cooperate with an investigation or prevent or address fraud, abuse, security, or technical issues.
  1. How do we protect and secure your personal data?

We are committed to protecting and securing your personal data from unauthorized access, use, disclosure, alteration, or destruction. We implement appropriate technical and organizational measures to safeguard your personal data, such as encryption, firewalls, access controls, and security audits. However, you acknowledge and agree that no method of transmission over the Internet or method of electronic storage is 100% secure, and that we cannot guarantee the absolute security of your personal data. You are responsible for protecting your account and password, and for limiting access to your devices and browsers.

  1. How long do we retain your personal data?

We retain your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests. The retention period of your personal data may vary depending on the type and purpose of the data, and the applicable laws and regulations. When we no longer need your personal data, we will delete or anonymize it, or, if this is not possible, we will securely store your personal data and isolate it from any further processing until deletion is possible.

  1. What rights and choices do you have over your personal data?

You have certain rights and choices over your personal data, depending on the laws and regulations that apply to you. These rights and choices may include:

  • Access. You have the right to access and obtain a copy of your personal data that we hold, subject to certain exceptions and limitations.
  • Correction. You have the right to correct or update your personal data that we hold, if it is inaccurate or incomplete.
  • Deletion. You have the right to request the deletion of your personal data that we hold, subject to certain exceptions and limitations.
  • Restriction. You have the right to request the restriction of the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Objection. You have the right to object to the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Portability. You have the right to request the transfer of your personal data that we hold to another service provider, subject to certain exceptions and limitations.
  • Withdrawal of consent. You have the right to withdraw your consent to the processing of your personal data that we hold, subject to certain exceptions and limitations.
  • Complaint. You have the right to lodge a complaint with a supervisory authority, if you believe that we have violated your data protection rights.

To exercise any of your rights and choices over your personal data, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform. We will respond to your request as soon as possible, and in any case within one month, unless we need more time to process your request, in which case we will inform you of the reason and the expected time frame. We may ask you to verify your identity and provide additional information or documentation to fulfill your request. We may also charge a reasonable fee or refuse to act on your request, if your request is manifestly unfounded, excessive, or repetitive.

  1. How do we use cookies and other tracking technologies?

Please refer to the Cookie Policy for more information on this section.

  1. How do we obtain your consent?

We obtain your consent to collect, use, and share your personal data in various ways, depending on the context and the purpose of the data processing. We may obtain your consent through:

  • Explicit consent. We may ask you to provide your explicit consent to collect, use, and share your personal data for specific purposes, such as sending you marketing and promotional communications, or sharing your personal data with our business partners. You can provide your explicit consent by clicking a button, checking a box, or performing a similar action that indicates your agreement. You can withdraw your explicit consent at any time by following the instructions on the Platform or contacting us at support@superfred.com.
  • Implicit consent. We may infer your implicit consent to collect, use, and share your personal data for certain purposes, based on your actions or behavior, such as accessing or using the Platform or any of its features, or connecting your social media accounts to the Platform. You can withdraw your implicit consent at any time by changing your settings on the Platform or on your device, or by deleting your account.
  • Legal consent. We may collect, use, and share your personal data without your consent, if we are required or permitted to do so by law, or if we have a legitimate interest that outweighs your privacy rights, such as protecting and securing the Platform and its users, or complying with any legal obligations or requests.

We will always inform you of the purpose and the legal basis of the data processing, and respect your rights and choices regarding your personal data.

  1. How do we handle children’s data?

The Platform is not intended for children under the age of 16, and we do not knowingly collect, use, or share any personal data from children under the age of 16. If we become aware that we have collected personal data from a child under the age of 16, we will delete such data as soon as possible, unless we are required or permitted to retain it by law. If you are a parent or guardian of a child under the age of 16, and you believe that your child has provided us with personal data without your consent, please contact us at support@superfred.com and we will take appropriate steps to delete such data and address your concerns.

  1. How do we transfer your personal data across borders?

We are based in Portugal, but we may transfer your personal data to other countries or regions that have different data protection laws and standards than your country or region of residence. For example, we may transfer your personal data to our service providers, business partners, or legal authorities that are located outside of your country or region of residence. We will only transfer your personal data across borders if we have a valid legal basis to do so, and if we ensure that your personal data is protected in accordance with this Policy and applicable laws and regulations. We will use appropriate safeguards, such as contractual clauses, to ensure the lawful and secure transfer of your personal data across borders.

  1. How do we respond to “Do Not Track” signals?

Some browsers and devices have a “Do Not Track” feature that lets you indicate that you do not want your online activity to be tracked. We do not currently respond to “Do Not Track” signals, as there is no uniform standard or consensus on how to interpret or implement them. However, we respect your rights and choices regarding your personal data, and you can always change your settings on the Platform or on your device, or delete your account, to limit or stop the collection and use of your personal data.

  1. Third-Parties.
  • Stripe

Fred utilizes Stripe for processing payments through the platform. Stripe collects certain personal information necessary for payment processing, including your name, billing address, credit card information, and email address. This information is stored securely by Stripe and is only used for the purpose of processing payments.

For more information on how Stripe collects and uses your personal data, please refer to their privacy policy: https://stripe.com/privacy

  • Google Analytics

Fred utilizes Google Analytics to collect and analyze website traffic data. This data helps us understand how users are interacting with the platform and allows us to improve its functionality and user experience. The data collected by Google Analytics includes:

  • Website traffic data: This includes information such as the number of visitors, the pages they visit, the length of their visit, and the sources of their traffic.
  • Device information: This includes information such as the type of device used, the operating system, and the browser version.
  • Location information: This includes information such as the country, city, and region of the visitor.
  • Demographic information: This includes information such as the age and gender of the visitor.

Google Analytics uses cookies and other tracking technologies to collect this data. You can learn more about how Google collects and uses data in its privacy policy: https://policies.google.com/privacy?hl=en-US

You can also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on: https://support.google.com/analytics/answer/181881?hl=en

Important Note:

By using Fred, you consent to the collection and use of your personal data by Stripe and Google Analytics as described in their respective privacy policies.

  1. How do we update this Policy?

We may update this Policy from time to time, to reflect changes in our data practices, the Platform and its features, or the applicable laws and regulations. We will notify you of any material changes by posting the updated Policy on the Platform and/or sending you an email. The date of the last update will be indicated at the top of this Policy. Your continued use of the Platform after any updates constitutes your acceptance of the new Policy. If you do not agree to the updated Policy, you must stop using the Platform and delete your account.

  1. How do we comply with the GDPR?

The General Data Protection Regulation (GDPR) is a data protection law that applies to individuals in the European Union (EU) and the European Economic Area (EEA). The GDPR grants individuals certain rights and choices over their personal data, and imposes certain obligations and responsibilities on data controllers and data processors.

We are a data controller with respect to the personal data that we collect and use on the Platform, and we are a data processor with respect to the personal data that we process on behalf of our users who are data controllers. We comply with the GDPR by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to access, correct, delete, restrict, object, port, withdraw consent, and complain.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within one month.
  • Cooperating with the supervisory authorities and complying with their decisions and guidance.

If you are an individual in the EU or the EEA, and you have any questions or concerns about our compliance with the GDPR, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. How do we comply with the CCPA?

The California Consumer Privacy Act (CCPA) is a data protection law that applies to individuals in California. The CCPA grants individuals certain rights and choices over their personal data, and imposes certain obligations and responsibilities on businesses that collect, use, or sell personal data.

We are a business under the CCPA, and we comply with the CCPA by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to know, access, delete, opt-out, and non-discrimination.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within 45 days.
  • Cooperating with the Attorney General and complying with their decisions and guidance.

If you are an individual in California, and you have any questions or concerns about our compliance with the CCPA, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. How do we comply with other data protection laws and regulations?

In addition to the GDPR and the CCPA, we may also comply with other data protection laws and regulations that apply to us or our users, such as the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Data Protection Act 2018 (DPA) in the UK, the Lei Geral de Proteção de Dados (LGPD) in Brazil, and any other applicable laws and regulations. We comply with these laws and regulations by:

  • Providing clear and transparent information about our data practices in this Policy and obtaining your consent where required.
  • Implementing appropriate technical and organizational measures to protect and secure your personal data from unauthorized access, use, disclosure, alteration, or destruction.
  • Respecting your rights and choices over your personal data, such as the right to access, correct, delete, restrict, object, port, withdraw consent, and complain.
  • Limiting the collection, use, and sharing of your personal data to the minimum necessary for the purposes stated in this Policy or as authorized by you.
  • Retaining your personal data for as long as necessary to provide and improve the Platform and its features, or to fulfill any legal obligations or requests.
  • Transferring your personal data across borders only if we have a valid legal basis and ensure adequate protection of your personal data.
  • Responding to your requests and inquiries regarding your personal data as soon as possible, and in any case within the time frame specified by the applicable law or regulation.
  • Cooperating with the relevant authorities and complying with their decisions and guidance.

If you have any questions or concerns about our compliance with any data protection laws or regulations that apply to you or your country or region of residence, please contact us at support@superfred.com or by using any other contact methods that we may provide on the Platform.

  1. Additional Privacy Policy Links

Google Privacy Policy: https://policies.google.com/privacy?hl=en-US

YouTube Terms of Service: https://www.youtube.com/static?template=terms

YouTube API Services Terms of Service: https://developers.google.com/youtube/terms/api-services-terms-of-service

How can you contact us?

If you have any questions, comments, or requests regarding this Policy or your personal data, please contact us at:

Christian Vondru, Email: support@superfred.com

We will use reasonable efforts to respond to your inquiries as soon as possible, and in any case within one month, unless we need more time to process your request, in which case we will inform you of the reason and the expected time frame. We may ask you to verify your identity and provide additional information or documentation to fulfill your request. We may also charge a reasonable fee or refuse to act on your request, if your request is manifestly unfounded, excessive, or repetitive.