Privacy Policy

Introduction

FR IDENTITY LTD (“we,” “our,” or “us”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our FR Digital ID mobile application (the “App”) and related services. Please read this privacy policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Personal Information

We may collect personal information that you voluntarily provide when using our App, including:

• Full legal name
• Date of birth
• Email address
• Phone number
• Government-issued identification document information (ID number, expiration date)
• Facial biometric data (for identity verification purposes)
• Profile photograph
• Address information

1.2 Automatically Collected Information

When you use our App, we may automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Usage data (app features accessed, time spent, interaction patterns)
• Log data (IP address, browser type, access times)
• Location data (with your consent, for verification purposes only)

2. How We Use Your Information

We use the information we collect for the following purposes:

• To verify your identity and create your digital ID
• To provide and maintain our services
• To process identity verification requests from authorized merchants
• To communicate with you about your account and our services
• To improve and optimize our App and services
• To detect, prevent, and address fraud, security issues, and technical problems
• To comply with legal obligations and regulatory requirements
• To enforce our terms of service and protect our rights

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 With Authorized Merchants

When you choose to verify your identity with a merchant (e.g., at a venue or for an online service), we share only the minimum necessary information required for that specific verification, such as:

• Age verification status (over/under a certain age)
• Identity verification status (verified/not verified)
• First name (optional, based on merchant requirements)

4.2 Service Providers

We may share information with third-party service providers who perform services on our behalf, such as cloud hosting, data analytics, and customer support. These providers are bound by contractual obligations to protect your data.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. Data Security

We implement robust security measures to protect your personal information:

• 256-bit AES encryption for data at rest
• TLS 1.3 encryption for data in transit
• Regular security audits and penetration testing
• Access controls and authentication mechanisms
• Secure data centers with physical security measures
• Employee training on data protection and security

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Maintain business records as required by law

When you delete your account, we will delete or anonymize your personal information within 30 days, except where retention is required by law.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your personal data
• Portability: Request transfer of your data to another service
• Restriction: Request restriction of processing
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, please contact us at gavrielron@walla.com

8. GDPR Compliance (European Users)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

• We process your data based on your consent, contractual necessity, or legitimate interests
• You have the right to lodge a complaint with your local data protection authority
• We will notify you of data breaches that may affect your rights within 72 hours

9. Children's Privacy

Our App is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at gavrielron@walla.com. We will take steps to delete such information.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, to protect your data during international transfers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date. For significant changes, we will provide additional notice via email or in-app notification. Your continued use of the App after any changes constitutes acceptance of the new Privacy Policy.