FREQUENTOR PRIVACY POLICY

Effective Date: December 17, 2025

1. Introduction

Frequentor (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (“App”). This policy applies to all users including customers, service staff (bartenders and servers), venue managers, and venue owners.

By using Frequentor, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our App.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide when you:

Create an account (name, email address, phone number, profile photo)
Connect with service staff or customers
Communicate through the App
Provide feedback or contact us

2.2 Location Data

Frequentor uses location services to provide core functionality:

Real-time location to identify nearby venues where your preferred staff is working
Venue check-ins and visit history (powered by Foursquare API)
Proximity-based push notifications when preferred staff members clock in at nearby locations

Location Data Protection:

All location data is encrypted in transit (TLS/SSL) and at rest (AES-256)
We collect only the minimum location data necessary for service functionality
Sensitive locations (healthcare facilities, places of worship) receive enhanced protection including anonymization and limited retention
Users maintain full control and can disable location services at any time in device settings
Location data is automatically purged according to defined retention schedules

2.3 Staff Work Schedule Information

For service staff members using Frequentor:

Clock-in and clock-out times
Current shift status (on shift/off shift)
Venue location where currently working

2.4 Venue and Business Data

For venue managers and owners:

Business information (venue name, address, hours of operation)
Point-of-sale (POS) and loyalty program data integration (when enabled)
Customer frequency, spending patterns, and preferences (for AI insights)
Staff schedules and performance metrics

2.5 Automatically Collected Information

Device information (device type, operating system, unique device identifiers)
App usage data (features used, time spent, interaction patterns)
Log data (IP address, access times, app crashes, system activity)
Push notification preferences and engagement

3. How We Use Your Information

We use collected information for the following purposes:

Provide core App functionality (connecting customers with service staff)
Send push notifications about staff availability and shift changes
Enable real-time updates of staff work schedules
Provide AI-powered insights to venue managers about customer behavior and profitability
Improve App performance, features, and user experience
Detect, prevent, and address technical issues or fraudulent activity
Communicate with you about updates, support, and promotional offers (with your consent)
Comply with legal obligations

4. Data Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Within the Frequentor Network

Customer profile information is shared with service staff you connect with
Staff work schedules and availability are shared with customers who follow them
Venue managers can access aggregated customer data and AI insights about their venue

4.2 Third-Party Service Providers

Foursquare API for location services and venue identification
Cloud hosting and storage providers
Push notification services
Analytics and performance monitoring services

All third-party providers are contractually obligated to protect your data and use it only for specified purposes.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government regulation, or to protect the rights, property, or safety of Frequentor, our users, or others.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will provide notice before your information becomes subject to a different privacy policy.

5. Data Security

We implement industry-standard security measures to protect your information:

Encryption of data in transit (TLS/SSL) and at rest (AES-256)
Role-based access controls limiting employee access to personal data
Regular security assessments and penetration testing
Secure authentication mechanisms
Incident response procedures for potential data breaches

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as your account is active or as needed to provide services. When you delete your account, we will delete or anonymize your personal information within 30 days, except where required by law or for legitimate business purposes (such as fraud prevention or financial recordkeeping).

Location data is automatically purged according to our retention schedules, with sensitive location data retained for the minimum time necessary.

7. Your Rights and Choices

You have the following rights regarding your personal information:

Access and Portability: Request a copy of your personal data in a portable format
Correction: Update or correct inaccurate information
Deletion: Request deletion of your account and personal data
Location Services: Disable location tracking in your device settings (this will limit App functionality)
Push Notifications: Opt out of push notifications in App settings or device settings
Marketing Communications: Unsubscribe from promotional emails
Object to Processing: Object to certain uses of your information

To exercise these rights, contact us at privacy@frequentor.com.

8. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

Right to know what personal information is collected, used, shared, or sold
Right to delete personal information
Right to opt-out of the sale of personal information (Note: we do not sell personal information)
Right to non-discrimination for exercising CCPA rights

9. European Privacy Rights (GDPR)

For users in the European Economic Area, we comply with GDPR requirements:

Legal basis for processing: consent, contract performance, legitimate interests, or legal compliance
Right to lodge a complaint with your local data protection authority
Right to withdraw consent at any time
International data transfers are protected by appropriate safeguards

10. Children’s Privacy

Frequentor is intended for users age 21 and older in the United States, and 18 and older in other jurisdictions. We do not knowingly collect personal information from children under these ages. If we discover that we have collected information from a child under the applicable age, we will delete it immediately. If you believe we have collected information from a child, please contact us at privacy@frequentor.com.

11. International Users

Frequentor is based in Texas, United States. If you access the App from outside the United States, your information may be transferred to, stored, and processed in the United States. By using the App, you consent to the transfer of your information to the United States and acknowledge that U.S. data protection laws may differ from those in your country.

12. Third-Party Links

The App may contain links to third-party websites, services, or venues. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy in the App and updating the “Effective Date” above. Your continued use of the App after changes become effective constitutes acceptance of the revised policy.

14. Venue Liability Disclaimer

Important Notice for Venues, Staff, and Customers:

Frequentor facilitates connections between service staff and customers independently of venue operations. Venues are NOT responsible or liable for:

Interactions, communications, or relationships between staff members and customers that occur through or are facilitated by the Frequentor App
Any harassment, altercations, disputes, or incidents involving customers and staff who have connected via Frequentor
Off-duty interactions or communications between staff and customers
Customer behavior towards staff that originates from or is related to connections made through the App

User Responsibility and Safety Features:

Users (both staff and customers) are solely responsible for their interactions and conduct. Frequentor provides safety features including:

Block feature allowing users to prevent unwanted contact
Report functionality for inappropriate behavior
Privacy controls over profile visibility and notifications

By using Frequentor, staff members acknowledge that their connections with customers are personal choices made independently of their employer. Venues and venue management are not party to these connections and bear no responsibility for outcomes resulting from such connections.

Users agree to hold venues harmless from any claims, damages, or liabilities arising from interactions facilitated through the App. For complete terms regarding liability, indemnification, and dispute resolution, please refer to our Terms of Service at www.frequentor.com/terms.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Frequentor

Email: admin@frequentor.com

Website: www.frequentor.com/privacy-policy

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By using Frequentor, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.