PRIVACY POLICY

    Last Updated: June 17, 2024

    INTRODUCTION

    Fren, a product of PhrenTech, Inc [https://fren.care] ("our" "we" or
    "us") respect the privacy and are committed to protect the personal
    information of our Users ("user," "you," your" or "yours") when you
    visit or use Fren, a product of PhrenTech, Inc [https://fren.care]
    (the "App"). We provide our App and Services (hereinafter
    collectively, either "App" or "Services") to you as under the
    following privacy policy (the "Policy").

    PERSONAL INFORMATION WE COLLECT

    In order to keep the App functional, we must process information about
    you to operate, improve, modify, customize, support and market our
    services.

    The type of information that we collect depends on how you use our App
    and Services. We require certain information to deliver to you, our
    services, and without this, we will not be able to provide such
    services to you. Our Services have optional features, which, if used
    by you, require us to collect additional information to provide such
    features. You will be notified of such collection, as appropriate. If
    you choose not to provide the information needed to use a feature, you
    will be unable to use the feature. Please carefully read the following
    to understand what information we may collect:

     	* When you use the App or register to the App, we may ask you to
    provide certain information, including EMAIL, NAME, PHONE, USERNAME,
    PASSWORD, CONTACT PREFERENCES OR CONTACT OR AUTHENTICATION DATA. We
    will also collect or otherwise ask you to provide additional
    information that you provide us, such as your profile details,
    pictures and/or any other texts, images, videos or information that
    you may upload on the App and/or provide to the App.
     	* Your financial information when you make purchases on the App. We
    collect financial information when you make a purchase on the Stripe
    [https://stripe.com/privacy], Elavon
    [https://www.elavon.com/privacy-policy.html] or other payment
    providers.
     	* We may also collect details about other social networks and linked
    accounts such as Google
    [https://policies.google.com/privacy?hl=en-US], Amazon and also
    information about your communications with us as well as communication
    with other users of our App, and we receive certain information, which
    they provide, such as TO CREATE USER ACCOUNTS, TO CONTACT USER, TO
    PROTECT YOUR SITE, PREVENT FRAUD OR TO PROVIDE SUPPORT.
     	* We also collect information while you access, browse, view or
    otherwise use the App. In other words, when you access the App we are
    aware of your usage of the App, and gather, collect and record the
    information relating to such usage, including geo-location
    information, IP address, device and connection information, browser
    information and web-log information, phone book and contacts, and all
    communications recorded by Users through the App. We use that
    information to enhance user experience, personalize your browsing
    experience as well as monitor the App for preventing fraud and
    inappropriate content or behavior. We collect texts, information,
    pictures, videos and/or any data that you may upload on the app. We
    also collect supplemental information obtained from third parties such
    as demographic and navigation data, if applicable. We combine your
    personal information with information we collect automatically or
    obtain from other companies and use it to improve and personalize our
    services, content and advertising and/or to prevent fraud.

    All of the preceding is collected, as permitted by applicable laws
    relevant to your jurisdiction.

     HOW DO WE COLLECT PERSONAL INFORMATION?

    INFORMATION PROVIDED BY YOU. You directly provide us with most of the
    information we collect. You do this by filling out the registration
    details on the App, linking accounts of other social networks to your
    Fren, a product of PhrenTech, Inc [https://fren.care] account,
    completing application forms, as well as by posting and sharing
    additional information voluntarily.

    INFORMATION WE COLLECT WHEN YOU USE THE APP. We collect technical
    information indirectly and automatically through our systems. This
    information includes logging your operating system, software
    configuration, Internet Protocol (IP) address and use of cookies
    (cookies are small files sent from us to your computer and sometimes
    back). Cookies ultimately help us improve your navigation and ease of
    use of our App.

    Should you require additional information about how we may use Cookies
    to improve the services we provide, please visit our COOKIE POLICY.

    INFORMATION WE COLLECT FROM OTHER SOURCES. We may receive information
    from third party vendors and/or other commercially available sources,
    such as:

     	* Third party vendors who provide us data to supplement the
    information we collect about you, in accordance with applicable laws.
    For example, we receive information from advertising and marketing
    partners in order to manage and measure our campaigns as well as from
    enrichment service providers to enhance, modify and personalize your
    experience of the App.
     	* If you link, connect, or login to your to your social media
    accounts with us, with a third-party service (e.g. Google
    [https://policies.google.com/privacy?hl=en-US], Amazon), we will
    receive certain profile information about you from your social media
    provider. The profile information we receive may vary depending on the
    social media provider concerned, but will often include your name,
    email address, friends list, profile picture as well as other
    information you choose to make public on such social media platform.
    Please note that we do not control, and are not responsible for, other
    uses of your personal information by your third-party social media
    provider. We recommend that you review their privacy notice to
    understand how they collect, use and share your personal information,
    and how you can set your privacy preferences on their sites and apps.
     	* For more information, please see the following sections of this
    Policy: ANALYTICS, COOKIES and MARKETING AND BEHAVIORAL REMARKETING

     HOW WE USE COLLECTED PERSONAL INFORMATION?

    All processing of your personal information will always be justified
    by a "lawful ground" for processing, where relevant under applicable
    laws. In the majority of cases, processing will be justified on the
    basis that:

     	* you, or in the case you are below the age of 16 or the age of
    legal adulthood if different in your country, your parent or guardian
    has provided consent for us to use your personal information for a
    specific purpose;
     	* the use of your personal information is necessary to perform a
    contract or take reasonable steps to enter into a contract with you
    (E.G. TO PROVIDE YOU WITH AGREEMENTS OR SERVICES WHICH YOU HAVE
    PURCHASED);
     	* the processing is necessary to comply with a relevant legal
    obligation or regulatory obligation that you and/or we have (e.g.
    fraud prevention); or
     	* the processing is necessary to support our legitimate interests as
    a business (e.g. to improve our services to you), subject to your
    interests and fundamental rights and provided it is conducted at all
    times in a way that is proportionate.

    We will use your personal information for the following purposes:

     	* To create user accounts.
     	* To contact user.
     	* We use information we have to verify accounts and activity; combat
    harmful conduct, protect users against bad experiences and spam; and
    promote safety, security and integrity on and off our Services, such
    as by investigating suspicious activity or violations of our Terms and
    policies, and to ensure our Services are being used legally. Safety,
    security and integrity are an integral part of our Services.
     	* To provide support.

     HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

    We retain personal information only for as long as is required to
    fulfil the purpose for which it was collected and unless otherwise
    stated for a period of: AS LONG AS THE USER HAS AN ACCOUNT WITH US.
    Please note that some circumstances, we will retain your personal
    information for longer periods of time. We will retain personal
    information for the following purposes:

     	* as long as it is necessary and relevant for our operations, e.g.
    as long as is necessary to provide services, etc.; and
     	* in relation to personal information to comply with applicable
    laws, prevent fraud, troubleshoot problems, assist with any
    investigation, enforce our App terms and take other actions as
    permitted by law.

     CHILDREN UNDER THE LEGAL AGE OF ADULTHOOD

    Our services are not directed to children under the age of thirteen,
    or any as such age relevant to Applicable Laws in your jurisdiction,
    and we do not knowingly collect personal information from children
    under the age of thirteen, or sixteen, through our Services. We
    encourage parents and legal guardians to help enforce our Privacy
    Notice by instructing children under the age of thirteen not to
    download or use our online services.

    Should we learn we have collected or received personal information
    from a child under 13 or any such age relevant to Applicable Laws in
    your jurisdiction, we shall delete that personal information
    immediately and if we shall have a reasonable doubt that the consent
    given is not truthful regarding the age of the user, we reserve
    ourselves the right to immediately suspend the access to the App
    giving notice of the reasons. If you believe we might have any
    information from or about a child under 13 or 16, or if you are a
    parent or guardian concerned that we may have collected information of
    your child, please contact us immediately at [email protected].

     SHARING PERSONAL INFORMATION WITH THIRD PARTIES

    We do not sell or rent your personal information to third parties for
    their marketing purposes without your explicit consent.

    We share your personal information with third parties as under:

     	* We share personal information with service providers that provide
    us with services for the purpose of operating the App and opening and
    operating your account. Consistent with applicable legal requirements,
    we take commercially reasonable steps to require third parties to
    adequately safeguard your personal information and only process it in
    accordance with our instructions;
     	* We share personal information to law enforcement agencies, public
    authorities or other parties, if we believe we are required to do so
    by law, or that doing so is reasonably necessary to comply with our
    legal obligations;
     	* We share personal information with payment processors, fraud
    detection agencies and similar third parties for the purpose of
    facilitating payments done via the App and securing the App and
    protecting it against fraud or other liabilities;
     	* We also may share limited personal information with such social
    media platforms and marketing partners, such as Facebook, Twitter and
    Google, to promote our services. Such features and third party
    services collect certain information about you and may set a cookie to
    enable their functionality. Such third party features are governed by
    their privacy policies and under their terms and conditions.
     	* Personal information will also be disclosed if we go through a
    business transition such as a merger, sale, transfer of all or a
    portion of Fren, a product of PhrenTech, Inc [https://fren.care] 's
    assets, acquisition, bankruptcy or similar event. In the event that we
    sell any business or assets, we will disclose your data to the
    prospective buyer. If we or substantially all of our assets are
    acquired by a third party, information held by us about our users will
    be one of the transferred assets.

    Please note, when you publish your information and/or share your data
    with other Users, we try to maintain the standards of all users, but
    we do not take responsibility over the actions of other users.

     WHERE WE STORE YOUR PERSONAL INFORMATION

    We may store your data manually or electronically. Any data stored
    electronically will be stored in secure servers, and any data stored
    manually will be stored in our premises within the UNITED STATES.
    Unfortunately, the transmission of information via the internet is not
    completely secure. Although we will do our best to protect your
    personal data, we cannot guarantee the security of data transmitted to
    us and any transmission is at your own risk.

     COOKIES

    We use cookies and similar technologies (such as web beacons, pixels,
    tags, and scripts) to improve and personalize your experience, provide
    our services, analyze performance and for marketing purposes.

    Some of the services we use such as GOOGLE ANALYTICS
    [https://policies.google.com/privacy], AMPLITUDE set cookies to allow
    us to gather anonymous data about your usage of our website.

    A cookie is a text file sent by a web server to a web browser and
    stored in the browser. The file is then sent back to the server each
    time the browser requests a page form the server. This enables the web
    server to identify and track the web browser.

    We may send a cookie which may be stored by your browser on your
    computer’s hard drive. The information we obtain from the cookie
    could be used to improve the website’s usability and for marketing
    purposes. We may also use that information to recognize your computer
    when you use our App and to personalize our App for you.

    Browsers usually will allow you to refuse cookies but this could have
    a negative impact on the usability of many websites.

    To learn more about how we and our third party service providers use
    cookies and your control over these Cookies, please see our Cookie
    Policy.

     DO NOT TRACK

    Do Not Track (DNT) is a privacy preference that users can set in some
    web browsers, allowing users to opt out of tracking by the web and
    online services. We do not honor browser requests not to be tracked
    online (known as "Do Not Track"), but our Cookie Policy describes how
    you can opt out of receiving cookies. To learn more about cookies,
    including how to view which cookies have been set and how to manage
    and delete them, please visit: www.allaboutcookies.org
    [https://allaboutcookies.org]. At this time, our App do not respond to
    Do Not Track beacons sent by browser plugins.

     ANALYTICS:

    We use GOOGLE ANALYTICS [https://policies.google.com/privacy],
    AMPLITUDE to collect the following information when users access or
    interact with our App: This information may include, among other
    information, the browser and operating system you are using, the URL
    or advertisement that referred you to our Website, the search terms
    you entered into a search engine that led you to our Website, areas
    within our Website that you visited, and other information commonly
    shared when browsers communicate with websites. This information may
    also include x/y coordinates of mouse events, unique ID tracking
    cookie, Internet Protocol ("IP") address (anonymized for residents of
    the European Economic Area), unique device identifier ("Device
    Identifier") for any device (computer, mobile phone, tablet, etc.). A
    Device Identifier is a number that is automatically assigned or
    connected to the device you use to access the Service, and our servers
    identify your device by its Device Identifier. Some mobile service
    providers may also provide us or our third party service providers
    with information regarding the physical location of the device used to
    access the Service.

    We use the information from GOOGLE ANALYTICS
    [https://policies.google.com/privacy], AMPLITUDE in order to assemble
    statistics regarding usage of our App as well as to help us understand
    how users engage with our App on an individual and aggregate basis in
    order to improve it; to help with customer service needs (such as
    troubleshooting issues that users report to us); and for research and
    analytical purposes such as service performance; customer behavior and
    common navigation through the App.

    We do not share our App traffic data with any third party for any
    purpose unless required for legal reasons such as meeting applicable
    laws, regulations, legal processes, or enforceable governmental
    requests and/or unless you have given an explicit consent to allow us
    to do so; enforcing applicable terms of service; detecting,
    preventing, or otherwise addressing fraud, security, or technical
    issues; protecting against harm to the rights, property or safety of
    our Company, our Customers, or the public as required or permitted by
    law.

    If you'd like to opt-out or If you'd like to obtain a copy of your
    data, make a correction, or have it erased, please contact us in any
    way convenient for you in the CONTACT US section.

     DISCLAIMERS:

     ADS AND EXTERNAL LINKS

    Please note that the App may contains links to third party Apps and
    advertisements, and if you link to a third party App from the App, any
    data you provide to that App and any use of that data by the third
    party are not under the control of Fren, a product of PhrenTech, Inc
    [https://fren.care] and are not subject to this Policy. You should
    consult the privacy policies of each App you visit. This Policy
    applies solely to personal information collected by our App. If you
    upload content, including personal information, to a social network
    and then tag the App, your submission will be subject to that social
    network's terms of use and privacy policy, even where you post on an
    official Fren, a product of PhrenTech, Inc [https://fren.care] page on
    the social network. We do not have control over these terms of use and
    privacy policies and have not reviewed their adequacy. You should
    therefore review these before submitting any personal information.

     HEALTH, MEDICAL, FITNESS AND NUTRITIONAL CONTENT

    If the App offers medical, fitness and nutritional information and
    content,you should not rely on this information as a substitute for,
    nor does it replace, professional advice, diagnosis or treatment.
    Should you have any concerns, or questions about your health, fitness
    or nutrition, you should always consult with a physician, an expert, a
    health care, fitness or nutrition professional.

    Not under any circumstance, should you avoid, delay or otherwise
    disregard seeking or obtaining professional advice because of
    something you may have read or seen on the App.

    Please note that the App only may offers medical, fitness and
    nutritional information and content as a free journalistic-blogging
    content and does not constitute a medical help provider whatsoever nor
    it solicits the use and/or purchase of medical devices or
    pharmaceutical product, unless they are of "free sale" category and do
    not require any special license or authorization.

    Unless explicitly stated and after a specific consent registration, we
    DO NOT COLLECT HEALTH RELATED DATA of the users and if you want to
    contact us and/or post questions and comments on the App regarding
    health, medical, fitness and nutritional matters, YOU ARE THEREFORE
    REQUESTED TO DO SO IN A MANNER THAT DOES NOT REVEAL YOUR PERSONAL
    INFORMATION (e.g. only post questions in a abstract fashion). We
    reserve ourselves the right to delete the contents that are not in
    compliance with such request.

     INCORRECT CONTENTS

    We take reasonable steps to ensure the accuracy of the information
    provide on the App and on the external link in this policy listed.
    However, the information is provided "as is" without any warranty of
    guarantee of any kind. Under no circumstance should you rely on the
    accuracy of information given on the App.

    We take no responsibility or liability for the accuracy, content,
    completeness, reliability or legality of the information and contents
    contained on this App.

     SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS

    This section of the Policy applies to you, if you are a California
    resident.

    We have collected the following categories of personal information
    from Users:

     	* Information that you chose to upload or otherwise provided by you
    which may include: (i) Identifiers and personal information, such as
    name, postal addresses, online identifiers, email addresses, and
    location.
     	* Information we collect when you use the App, including (i)
    Identifiers and personal information, such as online identifiers,
    internet protocol (IP) addresses, access device and connection
    information such as browser type, version, and time zone setting and
    browser plug-in types and versions; (ii) commercial information,
    including products or services purchased, obtained, or considered, or
    other purchasing or consuming histories or tendencies; (iii) Internet
    or other electronic network activity information, including, but not
    limited to log-in and log-out time, the duration of sessions, the
    content uploaded and downloaded, viewed web-pages or specific content
    on web-pages, activity measures; (iv) Location information, based on
    your IP address and GPS, (iv) phonebook based on your contact lists;
    (v) pictures based on your camera.
     	* Inferences drawn from any of the information identified above to
    create a profile about you.
     	* We obtain personal information listed above from third party
    sources, as detailed in this Policy.

    We use the personal information that we collect or receive for the
    business purposes as described above under the Section titled "HOW DO
    WE USE THE INFORMATION COLLECTED?".

    We disclose personal information to third parties for business
    purposes as described above under the Section titled "Sharing Personal
    Information with Third Parties" in the Policy. In the preceding twelve
    (12) months, we have disclosed all the categories of personal
    information detailed above for business purposes.

    As previously mentioned in this Policy, we do not sell (as such term
    is defined in the CCPA) personal information and will not sell it
    without providing Users with a right to opt out.

    You are entitled to the following specific rights under the CCPA in
    relation to personal information related to you:

     	* You have a right to request that we will disclose certain
    information to you about our collection and use of personal
    information related to you over the past 12 months. After verifying
    your request, we will disclose to you: (i) the categories of personal
    information that we collect about you; (ii) the categories of sources
    from which the personal information is collected; (iii) the purposes
    for collecting, using, or selling that personal information; (iv) the
    categories of personal information that we disclosed for a business
    purpose or sold, and the categories of third parties to whom we
    disclosed or sold that particular category of personal information;
    (v) the specific pieces of personal information that we have collected
    about you; (vi) if we disclosed your personal information for a
    business purpose, the categories of personal information we have
    disclosed; (vii) if we sold your personal information, the categories
    of personal information we have sold.
     	* You have a right to request that we delete personal information
    related to you that we collected from you under certain circumstances
    and exceptions.
     	* You also have a right not to be discriminated against for
    exercising your rights under the CCPA.

    To make such requests, we kindly ask that you contact us at
    [email protected].

    We will verify your request using the information associated with your
    account, including email address. Government identification may also
    be required.

    A request for access can be made by you only twice within a 12-months
    period. Any disclosures that we provide will only cover the 12-months
    period preceding receipt of your request. We do not charge a fee to
    process or respond to your verifiable User request unless it is
    excessive, repetitive, or manifestly unfounded. If we determine that
    the request warrants a fee, we will inform you of the reasons for such
    decision and provide you with a cost estimate before processing
    further your request.

     UPDATING PERSONAL INFORMATION

    We take steps to ensure that the personal information we collect is
    accurate and up to date, and we provide you with the opportunity to
    update your information through your account profile settings. In the
    event that you believe your information is in any way incorrect or
    inaccurate, please let us know immediately. We will make sure we
    investigate the matter and correct any inaccuracies as quickly as
    possible where necessary or give you ways to update it quickly or to
    delete it - unless we have to keep that information for legitimate
    business or legal purposes. When updating your personal information,
    we will ask you to verify your identity before we can act on your
    request. If for any reason you have a problem with deleting your
    personal information, please contact us at [email protected] and
    we will make reasonable efforts to delete any such information
    pursuant to any applicable privacy laws.

     CONTACT US

    To exercise any of your rights in connection with your personal
    information, we kindly ask that you please contact us at
    [email protected] .

    If you have any questions (or comments) concerning this Policy, please
    email our team at [email protected], and we will make an effort to
    reply within a reasonable timeframe.

    CONTACT US

    For any questions or queries regarding this Privacy Policy, please
    feel free to contact us:

    [email protected]