European Economic Area and United Kingdom Privacy Addendum

This European Economic Area and United Kingdom Privacy Addendum (the “EEA/UK Addendum”) supplements the Fraw Privacy Policy and applies to individuals located in the European Economic Area (EEA) or the United Kingdom (UK) who access or use the Fraw mobile application, website, software, official functions, extensions, creator tools, and related services collectively referred to as the “Service.”

The Service is operated by Untitled Labs Limited (“Fraw,” “we,” “us,” or “our”), a company incorporated in Hong Kong.

This EEA/UK Addendum should be read together with the Privacy Policy, the Fraw Terms & Conditions, the Creator & Diamonds Policy, and any other notices presented through the Service.

Capitalized terms not defined in this EEA/UK Addendum have the meanings given in the Privacy Policy or Terms & Conditions.

If this EEA/UK Addendum conflicts with the Privacy Policy, this EEA/UK Addendum will apply to individuals in the EEA and the UK to the extent required by applicable European or UK data-protection law.

Nothing in this EEA/UK Addendum excludes, restricts, or limits any right or protection that cannot lawfully be excluded, restricted, limited, or waived.

Matters Addressed by This Addendum

This EEA/UK Addendum supplements the Privacy Policy and provides additional information concerning:

• Fraw’s role as a controller;
• the purposes and lawful bases for processing personal data;
• legitimate interests;
• consent and withdrawal of consent;
• special-category and sensitive personal data;
• Face-Containing Images and AI image processing;
• processors, service providers, and other recipients;
• international transfers and applicable transfer safeguards;
• cookies, mobile SDKs, analytics, and similar technologies;
• data retention and deletion;
• automated processing, moderation, and decisions;
• access, rectification, erasure, restriction, objection, portability, and other data-protection rights;
• privacy-request procedures;
• supervisory-authority complaints;
• children’s personal data;
• security and personal-data-breach handling;
• creator, Diamond, withdrawal, and payout information;
• the current status of Fraw’s EU and UK representative arrangements; and
• other protections and obligations under applicable European and UK data-protection law.

This EEA/UK Addendum forms part of the Fraw Privacy Policy.