Privacy Policy

1. Introduction

Kozip Apparel OÜ ("we", "our", or "us") operates the Free to Hang mobile application and website at freetohang.com (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Estonian law.

By using the Service, you acknowledge you have read and understood this Privacy Policy. If you have any questions, contact us at info@freetohang.com.

2. Age requirement

The Service is intended for users aged 13 years or older. We do not knowingly collect personal data from children under 13. If you are under 13, please do not use the Service. If we become aware that a child under 13 has provided us with personal data, we will delete it immediately. Contact us at info@freetohang.com if you believe a child under 13 has created an account.

Our published child safety and CSAE prevention standards are available in our Child Safety Standards.

3. Personal data we collect

Data you provide directly

• Name and display name
• Email address (used for authentication)
• Username
• Profile photo (optional)
• Messages sent through in-app plan chats

Data collected automatically

• Device type and operating system version
• App usage data and feature interactions
• Push notification tokens
• Precise device location — only if you turn on location sharing in the app (see section 4)
• IP address and approximate location (country/region level)
• Crash reports and performance diagnostics

Social data

• Friends list (only users you explicitly connect with in-app)
• Availability status (visible only to accepted friends)
• Plans, hang requests, and related chat messages

Contacts (optional)

If you choose to find friends from your phone contacts, we process contact email addresses on our servers only to match them against registered users. We do not store your contact list after matching.

4. Location and the friends map

The friends map lets you see your friends and lets the friends you choose see you. Location sharing is optional and off until you turn it on.

• What we collect: your device's coordinates, their accuracy, and the time — while you use the app and, if you allow "Always" / "Allow all the time", also in the background, so friends can see you when the app is closed. On Android a notification is shown while background sharing runs.
• No history: we keep only your latest location. Each new point replaces the previous one.
• Who sees it: only accepted friends you allow — all friends, all except chosen ones, or only chosen ones. Never people you have blocked or who have blocked you, and never the public.
• Freshness: friends don't see a location older than 24 hours.
• Approximate mode: our server rounds your location to about 1 km before any friend receives it.
• Ghost mode: hides you for a set time or until you turn it off, and stops updates.
• Deletion: turning sharing off or turning on ghost mode deletes your stored location immediately. Deleting your account deletes it too.
• City suggestion: when location access is allowed, the app uses it on your device to suggest your city when you go free.

We process location on the basis of your consent (GDPR Art. 6(1)(a)). You can withdraw it at any time by turning sharing off in the app or removing location access in your device settings. We do not use your location for advertising, we do not sell it, and we do not send your coordinates to analytics providers.

5. Legal bases for processing (GDPR Art. 6)

6. How we use your data

• To provide, maintain, and improve the Service
• To show your availability status to your accepted friends
• To show your location on the friends map to the friends you choose (only if you turn location sharing on)
• To send push notifications (with your permission)
• To analyse usage patterns and improve performance (only with analytics consent)
• To respond to support requests submitted via the contact form
• To detect and prevent fraud, abuse, and security incidents
• To comply with legal obligations

We do not sell your personal data. We do not use your data for advertising targeting or profiling for commercial purposes.

7. Third-party processors

We use the following sub-processors. Each has a Data Processing Agreement (DPA) in place where required:

"SCCs applied" means we rely on EU Standard Contractual Clauses for transfers to countries outside the EEA, in accordance with GDPR Chapter V.

8. Data retention

• Account data — retained while your account is active. Deleted immediately upon account deletion.
• Chat messages and plan data — deleted with your account.
• Location — only the latest point is kept. Hidden from friends after 24 hours; deleted when you turn sharing off, turn on ghost mode, or delete your account.
• Contact form submissions — retained for up to 12 months then deleted.
• Anonymised analytics data — may be retained indefinitely as it cannot identify individuals.
• Legal/compliance records — retained as required by Estonian law (generally up to 7 years).

9. Your rights under GDPR

As an EU/EEA resident you have the following rights. To exercise any of them, contact us at info@freetohang.com. We will respond within 30 days.

10. Right to lodge a complaint

If you believe we have not handled your data correctly, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon):

11. Security

We implement industry-standard security measures including TLS encryption in transit, row-level security (RLS) policies on our database, and access controls limiting who can view personal data. However, no system is 100% secure — if you discover a security issue, please report it to info@freetohang.com.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the app or by email at least 14 days before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the Service after changes constitutes acceptance of the updated policy.

13. Contact

For any privacy-related questions or to exercise your rights: