Privacy Policy

Last updated: April 15th 2026 — FROY B.V., registered in The Netherlands

1. Introduction

FROY B.V. (“FROY”, “we”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the FROY mobile application and related services (the “Service”).

Contact: support@froy.app

2. Data We Collect

We may collect the following categories of personal data:

a) Account & Identity Data

First name or nickname
Date of birth or age
Nationality
Profile photo
Gender

b) Contact Data

Email address
Phone number (optional)

c) Location Data

Current city and nearby area
Location data required to match Locals and Visitors

d) Usage & Interaction Data

App activity
Requests, matches, ratings
Time, frequency, and duration of use

e) Communication Data

Limited chat messages used for coordination

f) Technical Data

Device type
Operating system
App version
IP address

3. How We Use Your Data

We use personal data to:

Create and manage user accounts
Enable connections between Locals and Visitors
Provide core app functionality
Ensure safety, trust, and moderation
Prevent misuse and fraud
Provide customer support
Comply with legal obligations

4. Commercial Use of Data

FROY may use personal data for commercial purposes, including but not limited to:

Improving and optimizing the Service
Analyzing user behavior and trends
Developing new features and offerings
Promoting FROY and its services
Offering premium features, partnerships, or sponsored experiences

Commercial use of data is always:

Proportionate and relevant
Compliant with GDPR / AVG
Based on legitimate interest and/or user consent

FROY does not sell personally identifiable data to third parties as a business model.

5. Data Sharing

We may share data with:

Service providers (hosting, analytics, verification)
Partners when necessary to deliver the Service
Authorities when legally required

All third parties are required to protect personal data in accordance with applicable laws.

6. Legal Basis (GDPR)

We process personal data based on:

Performance of a contract
Legitimate interests
Compliance with legal obligations
User consent (where applicable)

7. Data Retention

We retain personal data only as long as necessary to provide the Service, fulfill legal obligations, or protect our legitimate interests. When data is no longer required, it will be securely deleted or anonymized.

8. Your Rights

You have the right to:

Access your personal data
Correct inaccurate data
Request deletion
Object to certain processing
Withdraw consent

Requests can be sent to support@froy.app.

9. Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse.

10. Changes

We may update this Privacy Policy from time to time. Material changes will be communicated via the app.

11. Contact

For questions about this Privacy Policy: support@froy.app

12. Business Transfers

In the event that FROY is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, personal data may be transferred as part of such transactions. In such cases, we will ensure that the receiving party continues to protect personal data in accordance with applicable data protection laws and this Privacy Policy. Users will be informed of any material changes where required by law.

13. Child Safety & Protection

FROY has a zero-tolerance policy towards Child Sexual Abuse and Exploitation (CSAE).

Users may not use the Service to create, share, distribute, promote, solicit, or engage in any form of child sexual abuse, exploitation, grooming, trafficking, or other activity that endangers minors.

Any content, behavior, communication, profile, or account suspected of involving CSAE or the exploitation of minors may be immediately removed or suspended without notice.

FROY reserves the right to investigate reports, cooperate with law enforcement authorities, and take any action necessary to protect the safety of children and comply with applicable laws and regulations.

How to Report

Users can report safety concerns or suspected violations through the reporting tools available within the application. Reports can be submitted by accessing the chat with the relevant user and using the reporting feature. All reports are sent directly to FROY administrators for review and appropriate action.

The safety and protection of children is a fundamental priority of the FROY platform.