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Privacy Policy

Effective Date: August 21, 2026

1. Introduction and Controller Identity

This Privacy Policy governs the collection, processing, retention, and cryptographic management of personal data by Frayne ("We", "Us", "Our"), an application developed and operated by FRAYNE LABS LTD, acting as the primary Data Controller under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA). We are fundamentally committed to processing Your personal data with strict adherence to lawful, transparent, and secure methodologies. By accessing, downloading, or utilizing the Frayne application and its associated backend routing services, You acknowledge the data processing practices detailed comprehensively within this Policy.

Corporate Identity: FRAYNE LABS LTD is a company registered in England and Wales (Company No: 17405284), with its registered office located at 5 Oakland Avenue, Cheltenham, GL52 3EP, United Kingdom.

2. Categorization of Processed Data and Purpose Limitation

We process data strictly adhering to the principles of data minimization and purpose limitation. Data is categorized and processed as follows:

2.1 Identity and Authentication Data:

When You authenticate Your account via supported third-party identity providers (e.g., Apple ID, Google Account), We securely receive Your designated name, email address, and profile avatar. This data is utilized exclusively for identity verification, account security, and the provisioning of cloud-synchronized services.

2.2 Financial and Subscription State Data:

For users accessing Frayne Premium subscriptions, all financial transactions and billing operations are processed directly by the Apple App Store or Google Play Store, with cross-platform subscription entitlement state synchronized via Our sub-processor, RevenueCat. We do not collect, process, intercept, or store raw financial instruments (e.g., credit card numbers or billing addresses). We retain only a cryptographic App User ID, transaction timestamps, and real-time entitlement statuses to administer Your premium access rights, enforce query allowances, prevent fraud, and comply with applicable consumer protection regulations, including the Digital Markets, Competition and Consumers Act 2024 (DMCC).

2.3 Geolocation, Telemetry, and Routing Data:

2.4 Push Notifications, Crash Diagnostics, and Support Inquiries:

3. Lawful Basis for Processing

Under Article 6 of the UK GDPR, Our data processing activities are predicated on the following lawful bases:

4. International Data Transfers and Sub-Processors

To provide a globally resilient infrastructure with low-latency routing, We utilize highly vetted third-party sub-processors. Consequently, Your data is routinely transferred outside the United Kingdom. We ensure all such international transfers comply rigorously with Chapter V of the UK GDPR:

5. Data Retention Schedules and Cryptographic Anonymization

Data is retained only for the active lifecycle of Your account. In accordance with Article 17 of the UK GDPR (Right to Erasure), You possess the unambiguous right to mandate the immediate deletion of Your account and associated telemetry. Invoking the account deletion function via the in-app Service interface or at https://frayne.app/delete_account triggers an automated, irreversible cascade that purges Your authentication identity, historical routing data, user settings, and OAuth tokens from Our active operational databases.

6. Your Statutory Rights under UK GDPR

You are vested with comprehensive statutory rights regarding the processing of Your personal data:

To exercise these rights, navigate to the privacy controls within the application or initiate a formal request via our designated Data Protection Officer at support@frayne.app.

7. Statutory Data Protection Complaints Procedure (DUAA 2025 Compliance)

Pursuant to Section 164A of the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 (DUAA), We operate a mandatory, statutory internal complaints procedure. If You believe We have infringed upon Your data protection rights, mishandled Your data, or failed to honor a data subject access request, You must first raise the issue directly with Us before escalating the matter to regulatory authorities.

8. Minors and Age Limitations

The Frayne application is explicitly not designed for, nor directed at, individuals under the age of thirteen (13). We do not knowingly collect or process personal data from minors. If We become aware that a minor has provisioned an account, We will take immediate steps to summarily erase such information from Our servers.