Privacy Policy

Posted: September 3, 2024

We’ve written our Privacy Policy as simply as possible to empower you to make informed decisions when you use Frankly by making sure you understand and have control over the information we collect, how it’s used, and when it’s shared.

1. Information We Collect

2. How We Use Information

3. Sharing Information

4. How Long We Keep Information

5. Take Control

6. Your Rights and Ours

7. Frankly's Audience

8. Changes To This Privacy Policy

9. How To Contact Frankly

1. Information We Collect

The information we collect when you use Frankly falls into three categories.

1.1 Information you provide us.

To use some of our products and services you need to have an account, and to create an account, you need to provide us certain information. Likewise, if you use our paid products and services, we cannot provide them to you without getting payment information. Basically, certain information is necessary if you want to use many of our products and services.

Personal Accounts. If you create an account, you must provide us with some information so that we can provide our services to you. This includes your name (for example, “Jim Smith”); a password; an email address or phone number; the address at which you are registered to vote; and third-party single sign-in information (if you choose this sign-in method). Your display name and Congressional District are always public.

1.2 Information we collect when you use Frankly.

When you use our services, we collect information about how you use our products and services. We use that information to provide you with products and services, to help keep Frankly more secure and respectful for everyone, and more relevant to you.

Usage Information. We collect information about your activity on Frankly, including:

Posts and other content you post (including the date, application, and version of Frankly).

Your interactions with other users’ content, such as reposts and likes.

How you interact with others on the platform, such as people you follow and people who follow you, including the contents of the messages, the recipients, and date and time of messages.

If you communicate with us, such as through email, we will collect information about the communication and its content.

We collect information on links you interact with across our services (including in our emails sent to you).

Device Information. We collect information from and about the devices you use to access Frankly, including:

Information about your connection, such as your IP address, browser type, and related information.

Information about your device and its settings, such as device and advertising ID, operating system, carrier, language, memory, apps installed, and battery level.

Your device address book, if you’ve chosen to share it with us.

Location Information. When you use Frankly, we collect some information about your approximate location to provide the service you expect.

Inferred Identity. We may collect or receive information that we use to infer your identity as detailed below:

When you sign into Frankly on a browser or device, we will associate that browser or device with your account. Subject to your settings, we may also associate your account with browsers or devices other than those you use to sign into Frankly (or associate your signed-out device or browser with other browsers or devices or Frankly-generated identiﬁers).

When you provide other information to Frankly, including an email address, phone number or address, we associate that information with your Frankly account. We may also use this information in order to infer other information about your identity, for example by associating your account with hashes of email addresses that share common components with the email address you have provided to Frankly.

When you access Frankly and are not signed in, we may infer your identity based on the information we collect.

Log Information. We may receive information when you view content on or otherwise interact with our products and services, even if you have not created an account or are signed out, such as:

IP address and related information; browser type and language; operating system; the referring webpage; access times; pages visited; location; your mobile carrier; device information (including device and application IDs); search terms and IDs (including those not submitted as queries); Frankly-generated identiﬁers; and identiﬁers associated with cookies. We also receive log information when you click on, view, or interact with links on our services, including when you install another application through Frankly.

Cookies and similar technologies. Like many applications, we use cookies and similar technologies to collect additional website usage data and to operate our services. Cookies are not required for many parts of our products and services such as searching and looking at public proﬁles. You can learn more about how we use cookies and similar technologies here.

Interactions with our content on third-party sites. When you view our content on third-party websites that integrate Frankly content such as embedded timelines or post buttons, we may receive log information that includes the web page you visited.

1.3 Information we receive from third parties.

When you use other online products and services, they may share information about that usage with us.

Developers and Publishers. Our business partners share information with us such as browser cookie IDs, Frankly-generated identifiers, mobile device IDs, hashed user information like email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Some of our ad partners also enable us to collect similar information directly from their website or app by integrating our advertising technology. Information shared by ad partners and affiliates or collected by Frankly from the websites and apps of ad partners and affiliates may be combined with the other information you share with Frankly and that Frankly receives, generates, or infers about you described elsewhere in this Privacy Policy.

Other Third Parties, Account Connections, and Integrations. We may receive information about you from third parties who are not our partners, such as other Frankly users, developers, and partners who help us evaluate the safety and quality of content on our platform, our corporate affiliates, and other services you link to your Frankly account. You may choose to connect your Frankly account to your account on another service, and that other service may send us information about your account on that service.

2. How We Use Information

Breaking down how we use the information we collect is not simple because of the way the systems that bring our services to you work. For example, the same piece of information may be used differently for different purposes to ultimately deliver a single service. We think it’s most useful to describe the five main ways we use information and if you have questions that are not answered, you can always contact us.

2.1 Operate, improve, and personalize our services.

We use the information we collect to provide and operate Frankly products and services. We also use the information we collect to improve and personalize our products and services so that you have a better experience on Frankly, including by showing you more relevant content, suggesting people and topics to follow. We may use the information we collect and publicly available information to help train our machine learning or artificial intelligence models for the purposes outlined in this policy.

We may use the information we collect from accounts of other services that you choose to connect your Frankly account to provide you features like cross-posting or cross-service authentication, and to operate our services.

We use your contact information to help others find your account if your settings permit, including through third-party services and client applications.

2.2 Foster safety and security.

We use information we collect to provide for the safety and security of our users, our products, services, and your account. This includes verifying your identity, authenticating your account, and defending against fraud, unauthorized use, and illegal activity. We also use the information to evaluate and affect the safety and quality of content on Frankly - this includes investigating and enforcing our policies and terms, as well as applicable law.

2.3 Measure, analyze and make our services better.

We use the information we collect to measure and analyze the effectiveness of our products and services and to better understand how you use them to make them better.

2.4 Communicate with you about our services.

We use the information we collect to communicate with you about our products and services, including about product updates and changes to our policies and terms. If you’re open to hearing from us, we may also send you marketing messages from time to time.

2.5 Research.

We use information you share with us, or that we collect to conduct research, surveys, product testing, and troubleshooting to help us operate and improve our products and services.

3. Sharing Information

You should know the ways we share your information, why we share it, and how you can control it. There are five general ways we share your information.

3.1 When you post and share.

With the general public. You are directing us to disclose that information as broadly as possible. Frankly content, including your profile information (e.g., name, profile pictures), is available for viewing by the general public. The public does not need to be signed in to view some content on Frankly. They may also find Frankly content off of Frankly, for example from search query results on Internet search engines.

With other Frankly users. Depending on your settings, and based on the Frankly products and services you use, we share:

Your interactions with Frankly content of other users, such as likes, and people you follow.

With partners. Depending on your settings, we also provide certain third parties with information to help us offer or operate our products and services.

3.2 With third parties & third-party integrations.

With service providers. We may share your information with our service providers that perform functions and provide services on our behalf, including payment services providers who facilitate payments; service providers that host our various blogs and wikis; service providers that help us understand the use of our services; applicant tracking system providers to send and receive applicant and job data to potential employers; and those that provide fraud detection services.

Third-party content & integrations. We share or disclose your information with your consent or at your direction, such as when you authorize a third-party web client or application to access your account or when you direct us to share your feedback with a business. Similarly, to improve your experience, we work with third-party partners to display their video content on Frankly or to allow cross-platform sharing. When you watch or otherwise interact with content from our video or cross-platform sharing partners, they may receive and process your personal information as described in their privacy policies. For video content, you can adjust your autoplay settings if you prefer that content not to play automatically.

3.3 When required by law, to prevent harm, or in the public interest.

We may preserve, use, share, or disclose your information if we believe that it is reasonably necessary to: comply with a law, regulation, legal process, or governmental request; protect the safety of any person, protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services; explain why we have removed content or accounts from our services (e.g., for a violation of Our Rules); address fraud, security, or technical issues; or protect our rights or property, or the rights or property of those who use our services.

3.4 With our Affiliates.

We may share information amongst our affiliates to provide our products and services.

3.5 As a result of a change in ownership.

We may share, sell, or transfer information about you in connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy. This Privacy Policy will apply to your personal information that is shared with (before and after the close of any transaction) or transferred to the new entity.

4. How Long We Keep Information

We keep different types of information for different periods of time:

We keep your profile information and content for the duration of your account.

Remember public content can exist elsewhere even after you remove it from Frankly. For example, search engines and other third parties may retain copies of your posts longer, based upon their own privacy policies, even after they are deleted or expire on Frankly.

Where you violate our Rules and your account is suspended, we may keep the identifiers you used to create the account (i.e., email address or phone number) indefinitely to prevent repeat policy offenders from creating new accounts.

We may keep certain information longer than our policies specify in order to comply with legal requirements and for safety and security reasons.

5. Take Control

5.1 Deleting your Information.

In the Profile section of the service, you can choose to deactivate and your data will be queued for deletion. When deactivated, your Frankly account, including your name and public profile, will no longer be viewable on Frankly for iOS and Android. For up to 30 days after deactivation it is still possible to restore your Frankly account if it was accidentally or wrongfully deactivated.

5.2 Authorized Agent Requests.

To submit a request related to access, modification, or deletion of your information, or someone else’s information if you are their authorized agent, you may also contact us as specified in the How To Contact Frankly section of our Privacy Policy below. We may require you to provide additional information for verification.

6. Your Rights and Ours

We provide Frankly to people all over the United States. However, your experience may be slightly different than users in other states to ensure Frankly respects local requirements.

6.1 We have specific legal bases to use your information.

Frankly has carefully considered the legal reasons it is permitted to collect, use, share and otherwise process your information.

7. Frankly's Audience

Our services are not directed to children, and you may not use our services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your state.

8. Changes To This Privacy Policy

The most current version of this Privacy Policy governs our processing of your personal data and we may revise this Privacy Policy from time to time as needed.

If we do revise this Privacy Policy and make changes that are determined by us to be material, we will provide you notice and an opportunity to review the revised Privacy Policy before you continue to use Frankly.

9. How To Contact Frankly

We want to hear from you if you have thoughts or questions about this Privacy Policy. You can contact us via our Privacy Policy Inquiries page or by writing to us at the appropriate address below.

Global New Media Holdings

Attn: Frankly

1975 Upper Ridge Road

Green Lane, PA 18054