We are committed to providing quality services and a safe environment for our users. This Privacy Policy is designed to help consumers (“you”) understand what information we collect, why it is collected, and how the information is used and shared.
Where reasonable and practicable, we will collect your personal informationonly directly from you. However, in certain circumstances, we may receive information from third parties. This Privacy Policy does not cover the actions of third parties. For more information on their practices, please refer to their privacy policies. We are not responsible for them.
Why We Collect Information
To provide our services and fulfill our contractual and operational obligations, we collect and process certain personal information for thefollowing purposes:
1. Support and Maintenance: To provide you with quality services and maintenance support, and to handle and meet your requests.
2. Improve Our Products and Services: We use certain technical, diagnostic,and usage information to enhance the performance, reliability, andf unctionality of our products and services. For example, your smart frames maystore data related to hardware or software failures and send this information to our servers for troubleshooting and system improvement.
3. Develop New Services: We may use aggregated and anonymized information derived from our existing services to develop and improve new service features.
4. Service Communications and Customer Care: To communicate with you about service updates, support, and other important notifications.
5. Protect Users, the Public, and Us: We use the collected information to improve the safety and reliability of our services. This includes detecting, preventing, and addressing fraud, unauthorized access, infringement, or illegal activities that may harm us, our users, or the public.
6. Comply with Laws and Legal Processes: To meet legal obligations and comply with applicable laws, regulations, and legal processes.
We Want You to Understand Types of Information We Collect as You Use Our Services
We collect information to operate and provide our Services. What information we collect and how that information is used depends on how you use our services and how you manage your privacy controls. We may collect information from you, such as：
Browsing and Device Information:
1. Device type and settings
2. Device ID and MAC address
3. Wi-Fi network name and connection data
4. Country and language settings configured on your device
5. Time and date of server access, error logs, crash reports, and software version numbers
6. When you add a subscription to your account, payment processing is handled by Google Payments or Apple Pay. We do not collect or store your payment card details. We receive limited information necessary to confirm your subscription status and service entitlement.
Location Information:
We collect general location information, such as country or region, to provide region-specific features, services, and data storage allocation.
Photo and Video Content:
Photographs and videos that you upload, store, or share through the Services, including associated meta data such as timestamps and file size.
User-Generated Content:
1. Calendars & Lists: Information about the events and tasks you create in your calendar or to-do lists.
2. Profile Information: Your avatar, nickname, email address, and other account-related information.
Linked Device Information:
1. Information about the devices you link to our services, including the device type and settings.
2. Information about other user accounts linked to the same device.
Third-Party Synchronization Information:
When you synchronize with third-party calendars or services, we collect data necessary to enable synchronization, such as events and appointments stored in those calendars.
What do We do with Information We Collect?
Improve Our Services: We use the information we collect to operate,maintain, and improve the quality, security, and functionality of our Services and user experience.
1. Share Your Information: We do not share your personal information with any companies, organizations, or individuals except in the following cases:
2. With Your Consent: We will share your personal information when we have your explicit consent, particularly when it involves sensitive personal data.
For Legal Reasons: We may share your personal information if we have a good-faith belief that it is necessary to:
- Comply with applicable laws, regulations, or legal processes
- Enforce our Terms of Service, including investigating potential violations
- Detect, prevent, or address fraud, security, ortechnical issues
- Protect the rights, property, or safety of us, ourusers, or the public as required or permitted by law
For External Processing: We may share your personal information with trusted affiliates and service providers who process data on our behalf solely for the purposes described inthis Privacy Policy and subject to appropriate contractual confidentiality andsecurity obligations.
Business Transfers: If we sell or transfer part of our business or assets (such as in a merger, acquisition, or reorganization), we may share your information as part of that transaction, subject to applicable data protection requirements.
[For European Economic Area (EEA) Residents only]
We process personal information for the purposes described above. Our legal basis for processing personal information includes:
(i) Performance of a contract, such as providing and maintaining the Services you request;
(ii) Legitimate interests, limited to the operation, security, and improvement of our Services and customer relationship management, excluding the processing of photo and video content;
(iii) Compliance with legal obligations and legal processes;
(iv) Your consent, where required by applicable law.
You may withdraw your consent at any time by contacting us as specified in the Contact Us section of this Privacy Policy. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.
[For California Residents Only]
This section applies solely to residents of the State of California and is provided in accordance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).
Categories of Personal Information Collected
We may collect the categories of personal information described in this Privacy Policy, including identifiers (such as email address and device identifiers), internet or network activity information, general location information, and user-generated content (such as photos and videos uploaded through the Services).
Purposes of Collection
We collect and use personal information for the business and commercial purposes described in the section titled “What do We do with Information We Collect?”, including to operate, maintain, and improve our Services, provide customer support, and comply with legal obligations.
Disclosure of Personal Information
We may disclose personal information to service providers and affiliates for business purposes, as described in this Privacy Policy. We do not sell personal information for monetary consideration, and we do not share personal information for cross-context behavioral advertising purposes.
Your California Privacy Rights
(i) Subject to certain exceptions, California residents have the right to:
(ii) Request access to thepersonal information we have collected about you;
(iii) Request correction of inaccurate personal information;
(iv) Request deletion of your personal information;
(v) Limit the use and disclosure of sensitive personal information, where applicable.
Exercising Your Rights
You may exercise your California privacy rights by contacting us at help@whaleframely.com. We will verify your request using information associated with your account and respond in accordance with applicable law.
No Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA/CPRA.
Protection of Your Photographs and Videos
We protect your photo and video content with industry-standard technical and organizational security measures, including:
(i) Photo and video content you provide is stored on servers operated by our secure cloud hosting providers and protected by appropriate access controls;
(ii) Photos and videos are transmitted to your Whale Framely device using encrypted protocols and are not accessible to unauthorized third parties;
(iii) We will not share your photo or video content with third parties unless you provide explicit instructions through the Services to do so, such as when you select family members or others to receive content on their devices,or where sharing is required to comply with applicable law or a valid legal request.
Third-Party Services
If you choose to use or link our Services with third-party services, such as syncing your online accounts with our calendar, we will use the information we collect to authenticate you, provide the Services you request, and transmit data to and from the relevant third-party service strictly in accordance with your instructions and selections within the Services.
Third-party services that you choose to use in connection with our Services operate independently and maintain their own privacy and data protection practices, which may differ from ours. This Privacy Policy does not apply to the data practices of such third parties where they process personal information for their own purposes or on behalf of others. We do not control and are not responsible for such third-party activities. We encourage you to review their privacy policies to understand how they collect and use your information.
Third-party Calendar Services
Purpose: To support the proper use of calendar features, including accessing user-authorized calendar event information, displaying events within the app, and syncing calendar data to the local device.
Data may be obtained via APIs from third-party calendar service providers (such as Google or Microsoft), including:
Calendar event information: event title, event time (start time and end time), event reminders, event description
Calendar configuration information: calendar account identifier, calendar type (primary calendar or secondary calendar)
We prioritize your privacy by only accessing the data required for the feature to function. The data from the calendar feature is not sold to any third party, and it is transmitted between your calendar provider and the device. This datais only stored (cached) on the device to the extent necessary to provide the service. We may use anonymized analytics for the ongoing optimization of our services.
About Google Firebase Services
Purpose: Whale Framely may occasionally use Google Analytics to help measure and optimize the product, so as to better meet your needs, including crash monitoring and analysis, and product usage analytics.
The following technical data may be processed:
Device information: device model, operating system version, device language settings,device screen resolution
App information: app version number
Crash and performance data: crash logs
While we do not use this information to directly identify you, Google may store and process this data for its own purposes, and in certain cases, they may combine it with other information previously obtained about you, thereby identifying you. Such processing is subject to Google's own privacy practices. You may opt out by declining anonymous analytics data in our products.
Transfer of your Personal Information
Your personal information may be processed, accessed, stored, or transferred outside the country or region in which you are located, including by our affiliates and service providers, depending on the nature of the Services and how they are provided. Where such processing or transfer occurs, it will be carried out in accordance with applicable data protection laws and regulatory requirements, and subject to appropriate safeguards where required.
We may use servers or service infrastructure located in different jurisdictions, and your personal information may therefore be processed on servers located outside the country or region in which you are located, where relevant to the provision of the Services.
If you are located in the European Economic Area, please note that your personal information may be transferred to, accessed from, or processed in countries outside the European Economic Area. Where required under applicable law, such transfers will be carried out subject to appropriate safeguards in accordance with applicable data protection laws.
Information Sharing
We may share your personal information with our subsidiaries, affiliates, and service providers who perform services on our behalf, solely for the purposes described in this Privacy Policy. We do not authorize our service providers to use or disclose personal information except as necessary to perform services for us or to comply with applicable legal requirements.
We may also share personal information with third-party services or partners where you explicitly choose to connect or integrate such services withour Services, and only in accordance with your instructions and selections.
In addition, we may disclose personal information in the circumstances described in this Privacy Policy, including:
(i) Where you request or authorize us to do so;
(ii) Where disclosure is required by applicable law, regulation, or legal process;
To law enforcement authorities or government agencies where permitted orrequired by law;
(iii) Where we believe disclosure is necessary to protect the rights, property, or safety of us, our users, or others, or to investigate or preventfraud or illegal activities;
(iv) In connection with a merger, acquisition, reorganization, or other transfer of all or part of our business or assets, subject to applicable data protection requirements.
How Secure is Your Personal Information?
We use industry-standard technical and organizational measures to protect our electronic databases of personal information. However, you should be aware that no organization can fully eliminate all security risks associated with the processing of personal information.
Our products are designed with security considerations in mind, and we implement measures intended to protect personal information against unauthorized access, disclosure, alteration, or destruction. Information obtained through the maintenance and operation of our Services may be used to identify, assess, and address potential security threats.
Where required by applicable law, and where appropriate, we will notify you of a personal data breach and provide information on steps you may take to help protect yourself.
We work to protect personal information through a combination of technical and organizational safeguards, including:
(i) Using encryption to protect personal information during transmission;
(ii) Reviewing our information collection, storage, and processing practices to reduce the risk of unauthorized access to our systems;
(iii) Restricting access to personal information to employees, service providers, and vendors who require such access to perform their duties, all of whom are subject to contractual confidentiality and data protection obligations.
However, please note that despite our reasonable efforts, no website, internet transmission, computer system, or wireless connection is completely secure.
How Long do We Store Personal Information?
We will not retain your personal information for longer than is necessaryto fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law. When personal information isn o longer required, it will be securely deleted or anonymized in accordance with our data retention practices.
We take appropriate steps to ensure that we process and retain personal information based on the following criteria:
For the duration necessary to provide you with the relevant Services or features;
As required to comply with applicable laws, regulations, contractual obligations, or statutory requirements;
For as long as necessary for the purposes for which the information was collected and processed, or longer where required by applicable law orpermitted for legitimate purposes such as accounting, tax, or audit obligations, subject to appropriate safeguards.
We generally retain personal information only for as long as it is needed to provide the Services or as otherwise described in this Privacy Policy. Aggregated or anonymized data may be retained for longer periods where necessary for statistical analysis, reporting, tax, or audit purposes.
You Are in Control
Your personal information belongs to you. You may request information aboutthe personal data we process about you, and you may ask us to correct, update, or delete such information in accordance with applicable law.
You have the right to request access to your personal information that we process. Subject to applicable law, you also have the right to:
(a) Request correction (rectification) of inaccurate personal data or request erasure of such data in certain circumstances;
(b) Request restriction of processing of your personal data or object to such processing, where applicable;
(c) Request erasure of your personal data, including the “right to be forgotten,” where legally applicable;
(d) Request to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit such data toanother controller where technically feasible (data portability).
You also have the right to withdraw your consent at any time, where processing is based on your consent. Please note that such withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.
You may also use the relevant functionality provided in the software toremove cookies and login details. Please note that requesting deletion of your personal information may result in the loss of access to certain Services. We will not delete personal data that we are required to retain under applicable law or for legitimate legal or regulatory purposes.
Children’s Personal Information
Unless otherwise specified, the Services are designed for a general audience and are not directed to children. In connection with the Services, wedo not knowingly solicit or collect personal information from children below the applicable minimum age required by law (generally under the age of 16 int he European Economic Area and under the age of 13 in the United States) without verifiable parental consent, where required.
If we become aware that we have collected personal information from a child below the applicable minimum age without the required parental consent, we will take reasonable steps to either obtain such consent or promptly delete the information, in accordance with applicable law.
If you believe that a child below the applicable minimum age may have provided us with personal information without parental consent, please contactu s as specified in the Contact Us section of this Privacy Policy.
Data stored remotely
To obtain a copy of your data stored on Whale Framely’s servers, please contact our support team at help@whaleframely.com. Upon receiving a valid andverifiable request (including necessary identity verification), we will provide a copy of the personal data associated with your Whale Framely account withinthe timeframe required by applicable data protection laws.
Where technically feasible, the data will be provided in a structured, commonly used, and machine-readable format (such as JSON or ZIP), in accordance with applicable data portability requirements. We do not charge a fee for such requests, except where permitted by law.
Deletion of data
You may request to update, correct, or delete your personal data and preferences at any time by contacting us at help@whaleframely.com
If you terminate your subscription service, your account data will beretained for a limited period (generally up to 30 days) to allow you to exportyour data, during which we may notify you of the applicable retention period and data export options via in-app notifications or other reasonable means.
If you request deletion of your account, we will take reasonable steps to delete your personal data without undue delay, subject to applicable law. Please note that certain information may be retained where required by law, to comply with legal or regulatory obligations, to resolve disputes, or to enforce our agreements.
Any approved updates, corrections, or deletions will be reflected in ouractive systems within a reasonable period of time, depending on the nature oft he request and applicable technical or legal requirements.
Updates
This Privacy Notice may be updated periodically to reflect changes in our personal information practices with respect to our Service or changes in the applicable law. We will post a notice on our website and/or your device to notify you of any significant changes to our Privacy Notice, and indicate at the top of the notice when it was most recently updated.
Contact Us
You can send us an e-mail to help@whaleframely.com in your own language. You can send to this e-mail address if you have any question regarding our privacy policy, and we would like to request a copy of your personal data, or tell us in advance if you want us to change or delete your personal data.
[For European Economic Area (EEA) Residents Only]
You can also contact us at:
European Data Protection Officer
Raymond,
Marten Meesweg 8,3068 AV Rotterdam
Last Updated: 2026/3/30
