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Fraily

Privacy Policy

Last updated: April 21, 2026

1. Data Controller

The party responsible for data processing on the website fraily.app and in the app “Fraily” is: Nick Lehmacher (Sole Proprietor) Gerhart-Hauptmann-Str. 45a 90513 Zirndorf, Germany Email: hallo@fraily.app

2. Website – Google Analytics 4

This website uses Google Analytics 4 (GA4), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. GA4 helps us understand which content interests you and how to improve the site. Processing only begins after your explicit consent via the cookie banner (Art. 6 (1)(a) GDPR, § 25 (1) TTDSG).

3. Website – Data Processed

As long as you do not consent, no analytics cookies are set. After your consent we collect, among others, truncated IP address, device type, browser, pages visited, time on page and interactions (e.g. App Store button clicks, quiz progress, scroll depth). Your IP address is anonymized by Google before storage (anonymize_ip).

4. Website – Retention & International Transfer

Data is stored in GA4 for up to 14 months and may be transferred to the USA. Google is certified under the EU-US Data Privacy Framework, which ensures an adequate level of data protection.

5. Website – Revoke Consent

You can revoke your consent at any time with effect for the future. To do so, clear the stored consent in your browser – on your next visit the cookie banner will appear again and you can decide anew.

6. Website – Contact Form

When you contact us via the contact form on the website, your name, email address, and message are transmitted to us by email. We use this data exclusively to process your inquiry (Art. 6 (1)(b) GDPR). The data is deleted once your inquiry has been fully processed.

7. App – What Data Is Collected?

Fraily places great importance on protecting your data. The app stores your data locally on your device by default. The following data may be processed:

  • Names and information about your contacts that you enter in the app
  • Conversation notes and topics you create
  • App settings and preferences
  • Subscription status (via the respective app store)

8. App – Local Data Storage

The data you enter (contacts, conversations, notes) is stored exclusively on your device. No transfer of this data to the provider's servers takes place. When you delete the app or your account, all local data is irrevocably deleted.

9. App – In-App Purchases and Subscriptions

The service RevenueCat is used for processing in-app purchases and subscriptions (Fraily Pro). The following data is transmitted to RevenueCat:

  • An anonymous app user ID
  • Purchase information (product, time, status)
  • Device platform (iOS/Android)

RevenueCat processes this data in accordance with its own privacy policy: https://www.revenuecat.com/privacy

10. App – App Store Data

When downloading or making purchases through the Apple App Store or Google Play Store, the privacy policies of the respective platform apply. The provider has no access to the data collected there (e.g. payment information).

11. App – Push Notifications

The app may send push notifications to remind you about contacts. A device token is used for this purpose. You can disable push notifications at any time in your device settings.

12. App – No Tracking or Analytics Tools

Fraily does not use any tracking tools, analytics SDKs, or advertising in the app. No user profiles are created and no data is shared with third parties for advertising purposes.

13. Your Rights (GDPR)

Under the GDPR, you have the following rights:

  • Right to access your stored data
  • Right to rectification of incorrect data
  • Right to deletion of your data
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing

Since your app data is stored locally, you can view, modify, or completely remove it at any time via “Settings” → “Delete Account”. For website-related inquiries, contact hallo@fraily.app.

14. Changes

This privacy policy may be updated from time to time. The current version is always available on this website and within the app.