Updated 18.02.2025
This privacy policy describes how The We Effect AS processes personal data related to the use of Frode.ai. The We Effect AS is the data controller for the activities described below. The words "we", "us" and "our" refer to the data controller. The words "you" and "your" refer to the data subject (the person about whom we process information).
If you have any questions or would like to exercise your rights as a data subject, you can find our contact information below.
The data protection officer is Andrei Gaspar (andrei@frode.ai).
In chapters 3-8 below, you will find information about what personal data we process and for what purposes.
Through our service Frode.ai, a digital conversation partner largely based on artificial intelligence (hereinafter referred to as "Frode.ai" or "Service"), we collect various types of personal data about you. We do this in order to provide the Service.
3.1 Personal data you share by creating a user account
In order to use Frode.ai, you must create an user account. You can log in using an existing Apple account, where we get access to your email address and your name, as well as information that Apple is used for login. Alternatively, you can log in by entering your email address and a password of your choice.
You may choose to share additional personal data with us that is linked to your user account, which we will process. This constitutes name, date of birth, gender and emergency cash (name and phone number).
We automatically collect and process various information about your device when you use the Service. This constitutes e.g. usage patterns, language, time zone, region/area, system of measurement, local currency, device ID, IP address, device/iOS/browser type and device token.
If you have accessed the Service through one of our partners (e.g. employer/companies/organizations), we will process information that you are affiliated with the partner.
If you have paid for the Service yourself, we will process information about the purchase you have made (e.g. type of subscription, duration and price). Your payment information is handled directly by Apple/Google and we have no insight into this.
This personal data is processed by us and our third-party suppliers because it is necessary for the Service to function. Thus, the processing is also necessary to fulfill the agreement with you.
3.2 Personal data that you share when using Frode.ai or that arises as a result of using Frode.ai
If you provide personal data (either directly or as combined personal data) about yourself or third parties in conversation with Frode.ai, this information will be processed in order to provide the Service.
The information you share with Frode.ai may include special categories of personal data, such as health information, etc. depending on what information you provide. You must consent to such information being processed when creating a user account. If you do not consent, you will not have access to Frode.ai.
Frode.ai may also generate new personal data in its communication with you. Regardless of whether this information is accurate or not, it will be defined as personal data and potentially special categories of personal data.
The legal basis for the processing is that it is necessary to fulfill an agreement with you, and that you have consented to the processing of special categories of data.
3.3 When the Service is paid for by a business
We may provide the Service to a business partner (employers, suppliers, organizations, etc.). In that case, we will either be a data processor or have a joint controller relationship with the business. Our partner is responsible for handing over your contact details to us so that we can create a user for you. We are responsible for the Service itself. We assume that our partners have a valid consent or other legal basis for sharing your contact information with us. If you do not want our partners to disclose your contact information, you can contact them. If you wish to exercise your rights in other ways, you can contact us directly.
You can get in touch with us through our website (contact form, support system, chat, etc.), via the Service, by phone or by sending us an email. In such cases, we process information about your name, affiliated company (if relevant), contact information and what you write/tell us when you contact us.
The purpose is to be able to interact with and respond to users, customers, website visitors and other stakeholders. The legal basis for the processing is that we have a legitimate interest in being able to respond and interact with people who contact us.
On the website www.frode.ai we use cookies to deliver the content of the website as well as to collect statistics and market our products and services.
The cookies we use to make the website work collect personal data such as which device you use, IP address and browser type.
The cookies we use for analytical purposes include information about the use of the website. The legal basis for our processing is our legitimate interest in providing a website to promote and provide information about our business to interested parties.
For statistical and marketing purposes, we will obtain your consent to the processing.
You can find updated information in the tool we use to obtain consent on the website.
We conduct user surveys to obtain information about our users and their use, experiences and input related to Frode.ai and our other services. It is voluntary to participate in such surveys, which are normally conducted through qualitative in-depth interviews or quantitative, digital surveys.
If you participate in a user survey, we will process information about your name, contact information, demographic information and other information requested by the survey.
The purpose is to collect information in order to improve Frode.ai and our other services. The legal basis for the processing is either that we have obtained consent (typically for in-depth interviews) or that we have a legitimate interest in developing and improving our products and services.
We are present on various social media platforms such as Instagram, Facebook and LinkedIn.
If you interact with us on these platforms (for example, by liking our posts or sending us messages), we will process information that appears in your social media profile. This typically includes your name/username and profile picture.
We are normally a joint controller with the provider of the platform, such as Meta.
Our basis for processing is that we have a legitimate interest in being present on platforms where we reach out to relevant users and stakeholders.
We enter into various types of agreements with customers, partners, suppliers and other contractual parties in order to run our business. In order to follow up and administer such agreements, we process personal data about the contact person(s) at our contractual partner. The personal data we process typically includes the name, contact information, position, employer and signature of the person representing the contracting party.
The legal basis for the processing is our legitimate interest in being able to administer and follow up our contractual relationships. We have assessed that this interest is not overridden by the interest of the data subject.
We process your personal data for as long as it is necessary to fulfill the purpose for which the personal data was collected. More specifically, this means that:
In certain situations, we may process the data for a longer period. This may be the case, for example, if it is necessary to continue processing the personal data in order to comply with a legal obligation or to establish, exercise or defend a legal claim.
10.1 Sharing of personal data with our data processors
We use data processors to perform some of the activities described above. Data processors act on our behalf and typically provide software systems to us to process personal data. We have entered into data processing agreements with our third-party suppliers where relevant.
We use the following types of data processors:
10.2 Sharing of personal data with third parties
We only share your personal data with third parties if we have a legal basis to do so. We share your personal data in the following situations:
If you are subject to the GDPR, we will not transfer your personal data that you share with us outside the EU/EEA, except as described below.
Some personal data, but never special categories of personal data, may be processed outside the EU/EEA. If such a transfer takes place, we will ensure that there is a legal basis for the transfer, such as a decision that the country we are transferring to has an adequate level of protection.
12.1 Overview of rights
This section describes certain rights you have as a data subject under the GDPR. Please do not hesitate to contact us if you have any questions about your rights or if you wish to exercise your rights. Please note that there may be certain exceptions to the rights set out below.
Insight
You have the right to obtain confirmation as to whether or not we process personal data about you. You can also request a copy of the personal data we process about you.
Correction of personal data
You can ask us to correct or amend information that is inaccurate or misleading, and to complete incomplete personal data.
Deletion of personal data
In certain situations, you can ask us to delete information about you. You can delete your personal data in the Frode.ai service by deleting your user account. You delete your user account by contacting us and requesting deletion. If you delete your user account, we may retain anonymized data.
Restriction of the processing of personal data
In certain situations, you can also ask us to restrict the processing of your personal data. This could be, for example, if you have contested the accuracy of the personal data we are processing and we are working to verify its accuracy, or if you have objected to our processing based on our legitimate interest.
Objection to the processing of personal data
If we process your data on the basis of a task carried out in the public interest or in the exercise of official authority vested in the controller, or on the basis of a balancing of interests, you have the right to object to the processing of your data. You may also object to our processing for direct marketing purposes, including profiling for such purposes. If you object to processing for direct marketing purposes, we are obliged to stop such direct marketing.
Data portability
When we process information about you on the basis of consent or to fulfill an agreement, you can ask us to transfer information about you to you or to another data controller, if technically possible.
You can complain about our processing of your personal data
We hope that you will let us know if you believe that we are not complying with the provisions of the General Data Protection Regulation or the Personal Data Act. If you wish to complain to us, please first notify us via the email indicated below.
You can also complain about our processing of personal data by contacting the Norwegian Data Protection Authority. You can find the contact details for the Norwegian Data Protection Authority at www.datatilsynet.no.
12.2 How to make use of your rights
You can exercise your rights by sending an email to hi@frode.ai or a letter to
The We Effect AS,
Bjørndalen 5, 5009 Bergen, Norway
Organization number 925336785
You have the right to receive a response without undue delay, and normally within one month at the latest.
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