Draft for legal review. This page has not been reviewed by counsel and is not yet in effect. Text marked [TBD: …] is a placeholder for a fact we have not confirmed yet.

Your rights in the EU and UK

Status: draft for legal review. Last updated: October 8, 2026.

This notice adds to our Privacy Policy for people in the European Economic Area, the United Kingdom, and Switzerland, under the General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection.

Who is responsible for your data

The controller of your personal data is QB ME LLC, which operates Frndo, [TBD: registered address]. Contact: privacy@frndo.app.

  • Data protection officer: [TBD: DPO name and contact, if one is appointed. Because Frndo processes sensitive data at scale, counsel should confirm whether a DPO is required.]
  • EU representative under GDPR Article 27: [TBD: name and address]
  • UK representative under UK GDPR Article 27: [TBD: name and address]

Why we process your data, and our legal bases

  • To provide Frndo to you (account, conversations, memory, avatar, settings): necessary to perform our contract with you (Article 6(1)(b)).
  • Sensitive information you share in conversation, such as health, mental wellbeing, religious beliefs, or sex life, and Health data from Apple Health: your explicit consent (Article 9(2)(a)). [TBD: describe how the app asks for explicit consent.]
  • Location and calendar: your consent, given through the iOS permission prompt (Article 6(1)(a)). You can withdraw it at any time in iOS Settings.
  • Security, fraud prevention, and keeping the service working (sign-in protection, audit logs, crash and performance telemetry): our legitimate interests in running a secure and reliable service (Article 6(1)(f)). You can object, as explained below.
  • Waitlist emails: your consent, given when you sign up (Article 6(1)(a)).
  • Complying with the law: legal obligation (Article 6(1)(c)).

Where we rely on consent, you can withdraw it at any time without affecting what happened before. Some features need certain data to work: for example, without your conversations, Frndo cannot reply.

Automated processing

Frndo uses AI to generate replies and to decide which memories to keep and recall. This shapes your conversations, but it does not make decisions about you that have legal or similarly significant effects, as described in Article 22.

International transfers

Our servers and most of our service providers are in the United States, so your data is transferred outside the EEA, the UK, and Switzerland. We protect these transfers using [TBD: transfer mechanism, for example the EU-US Data Privacy Framework and its UK extension, or the European Commission's Standard Contractual Clauses with the UK addendum]. To get a copy of the safeguards, email privacy@frndo.app. See Subprocessors for who receives data and where.

How long we keep it

See "How long we keep it" in the Privacy Policy.

Your rights

You have the right to:

  • Access (Article 15): get confirmation that we process your data, and a copy of it.
  • Rectification (Article 16): have inaccurate data corrected. You can also tell Frndo in conversation, or delete a wrong memory in the app.
  • Erasure (Article 17): have your data deleted. See Delete your account and data.
  • Restriction (Article 18): have us limit how we use your data in certain cases.
  • Portability (Article 20): receive the data you gave us in a structured, commonly used, machine-readable format, and have it sent to another service where technically feasible.
  • Objection (Article 21): object to processing based on our legitimate interests. We will stop unless we have compelling legitimate grounds, or need the data for legal claims.
  • Withdraw consent (Article 7(3)): at any time, for processing based on consent.
  • Complain to a supervisory authority (Article 77): in the EU country where you live or work, or where an alleged breach happened. In the UK, that is the Information Commissioner's Office (ico.org.uk). You can find EU authorities at edpb.europa.eu. We'd appreciate the chance to address your concern first.

How to use your rights

Email privacy@frndo.app from the email address on your account. We may ask you to confirm your identity. We'll respond within one month, which we may extend by two more months for complex requests; if we do, we'll tell you why. Using your rights is free unless a request is clearly unfounded or excessive.

[TBD: how you receive a copy of your data, and in what format.]

Providing data

You don't have to give us any data, but Frndo can't work without an account and your conversations. Location, calendar, and Health access are optional.