Friendly Captcha protects websites and online services from spam and abuse. Using proof-of-work, our solution employs a fundamentally new approach to spam prevention and therefore does not depend on tracking users and exploiting personal data.

Your privacy and your end users’ privacy are critically important to us. At Friendly Captcha, we have a few fundamental principles:

• We are thoughtful about the information that we collect through the operation of our services.
• We store information for only as long as we have a reason to keep it.
• We aim to make it as simple as possible for you to keep control over your data.
• We aim to make it as simple as possible for your end users to keep control over their data.
• We help protect you from overreaching government demands for your information.
• We aim for full transparency on how we gather, use, and share information.

Below is our Privacy Policy for Service Users, which incorporates and clarifies these principles. It is Friendly Captcha GmbH’s policy to respect your privacy regarding any information we may collect from you across our online service, https://friendlycaptcha.com, and other sites we own and operate.

Service Users are those who incorporate our service into their website.
End Users are individuals who interact with our service through the websites of our Service Users.

This Privacy Policy is only valid for Service Users.

1. Information we collect

Log data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

Device data

We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

• Name
• Email
• Phone/mobile number
• Work address
• Website address
• Payment information

Business data

Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

2. Legal bases for processing

We will process your information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

• it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
• it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to offer our services, to market and promote our services, and to protect our legal rights and interests;
• you give us consent to do so for a specific purpose; or
• we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% foolproof. If necessary, we may retain your personal information for our compliance with a legal obligation or to protect your vital interests or the vital interests of another natural person.

3. Use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our platform’s core features;
• to process any transactional or ongoing payments;
• to enable you to access and use our service, website, associated applications and associated social media platforms;
• to contact and communicate with you;
• for internal record keeping and administrative purposes;
• to operate and improve our service, associated applications and associated sites;
• for marketing, including to send you information about our services that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have; and
• to consider your employment application.

4. Sharing of information

We may only disclose personal information to:

• service providers for the purpose of enabling them to provide their services, including IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors and payment systems operators;
• our employees, contractors and/or related entities;
• credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; and
• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.

Friendly Captcha is a globally available service headquartered in Germany. We host our solutions in dedicated data centers and on the edge distributed across more than 200 data centers worldwide, which means that requests are routed to a data center close to the requester.

By providing us with your information, you consent that the information we collect is stored and processed where we and our service providers maintain facilities. We will ensure that any transfer of information will be protected by appropriate safeguards, by using the new standard data protection clauses approved by the European Commission or the use of binding corporate rules.

5. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of our services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

6. Cookies

We may use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. You can manage and delete cookies as you wish – for details, see https://www.aboutcookies.org. Please refer to our Cookie Policy for more information.

7. Business transfers

If we or our assets are transferred to another company, we would include data among the assets transferred to this company. You acknowledge that such transfers may occur, and that any parties who undertake our business operations may continue to use your personal information according to this policy.

8. Limits of our policy

Our website and service may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

9. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of our service after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

Data Controller: Service User that integrated Friendly Captcha
Data Processor: Friendly Captcha GmbH
Data Protection Officer: Dr. Sebastian Kraska, IITR Datenschutz GmbH
Technical Contact: Guido Zuidhof
Business Contact: Benedict Padberg
Address: Am Anger 3-5, 82237 Woerthsee, Germany
Email: privacy＠friendlycaptcha.com

This policy is effective as of April 23, 2024.