Privacy Policy

1. Introduction

This Privacy Policy describes how SLAY GmbH, with its registered office at Invalidenstraße 5, 10115 Berlin, Germany, owner of the W App, frfr, Pengu and Otakutie (referred to as "we", "our", or "us"), collects, uses, and shares your personal information when you use our Applications. We are committed to creating a trustworthy online environment for our users and to the ethical collection, use, and protection of your personal information.

2. Information We Collect

Directly Provided Information: This includes data you submit during account creation, participation in polls, or any other interaction on our Applications. Examples include your name, phone number, and other voluntary submissions.Contacts Information: If granted permission, we may sync your mobile device's contact list.Types of Data Processed: This encompasses contact details, content data, usage specifics, and meta/communication data.Usage Data & IT Infrastructure: Data related to your interactions and the technology used during your sessions.

3. Purpose of Data Utilization

Poll Creation & Participation: All polls on the platform undergo content moderation. This may involve sending notifications to your contacts.App Enhancement: Data helps refine our Applications and drive new feature development.Feedback, Communication, & Security: For improved communication, platform security, and better user experience.

4. Sharing and Retention of Data

We don’t sell or lease your personal data to third parties for marketing without clear consent. Situations where sharing might occur include:Poll Participation: Your participation status may be disclosed to the poll creator.Data remains with us for the necessary duration, or as mandated by law.

5. Children's Privacy & Policy Changes

W App and frfr aren’t designed for users below 13 years. Unintended data collection from these users results in immediate deletion of related accounts and data. We may periodically update this policy, with changes promptly displayed here. Continued use post-amendment signifies acceptance.

6. Legal Considerations & Jurisdictional Compliance

Our data processing stands on:Contractual Obligations: (Art. 6 (1) p. 1 lit. b) DSGVO) - For contract fulfillment.Legitimate Interests: (Art. 6 (1) p. 1 lit. f) DSGVO) - Necessary processing given it doesn't infringe upon user rights.National Regulations: For German users, the BDSG, especially regarding employee data, is observed. This policy adheres to data protection laws in Germany, the U.K., the U.S., and Australia.

7. Security Measures

We take appropriate technical and organizational measures, including TLS encryption, to safeguard your data. This ensures data confidentiality, integrity, and availability, among others.

8. Data Transfer

Data may be shared with other entities like service providers. We ensure legal compliance and proper protection during such exchanges.

9. Data Processing in Third Countries

Data processing outside the EU/EEA follows legal requirements and ensures an appropriate data protection level.

10. Data Deletion

Data will be deleted as per legal requirements unless needed for specific lawful purposes.

11. Provision of the Online Offer and Web Hosting

User data is processed to provide online services, including collecting access data and log files. Data in log files are stored for a maximum of 30 days, after which they're deleted or anonymized unless needed for evidence in specific incidents.

12. Contact & Queries

For inquiries regarding this policy or data practices, connect with us at

U.S. Data Protection Compliance

Compliance with the California Consumer Privacy Act (CCPA):

If you are a resident of California, you are granted specific rights regarding access to your personal information under the CCPA.Right to Know and Access: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you specifically.Right to Delete: You have the right to request the deletion of your personal information collected or maintained by us.Right to Opt-Out: We do not sell personal information, but if we ever engage in such practices in the future, you have the right to opt-out.Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.To exercise your CCPA rights, please contact us at

Protection of Contact Book and SMS Data:

When you grant us permission to access your contact list or SMS, we use this data solely to facilitate the services of W-App, such as locating contacts and sending poll participation notifications. We don't sell or share your contact list or SMS data with third parties. If we ever decide to use your contact list or SMS data differently, we will seek your explicit consent first.

Data Security Measures in the U.S.:

We are committed to the security of your data and have implemented rigorous security measures in compliance with U.S. data protection laws. Our infrastructure employs state-of-the-art encryption, firewalls, and regular security audits to protect against unauthorized access, use, or disclosure of your personal information.

U.S. Children's Online Privacy Protection Act (COPPA) Compliance:

W-App complies with COPPA. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use W-App. If you are under 13, please do not send any information about yourself to us. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible.

Changes to the Policy

We may modify this Privacy Policy at any time. If we do, we will notify you by posting the changes on this page. Your continued use of W-App after any modification constitutes your acceptance of the updated Privacy Policy.This Privacy Policy is governed by the laws of the United Kingdom, Germany, and Australia, depending on the location of the user.If you have any questions about this Privacy Policy, you can contact us at

Types of data processed

- Contact details
- Content data
- Usage data
- Meta/communication data

Categories of affected persons

- Communication partner
- Users

Processing purposes

- Contact requests and communication
- Security measures
- Managing and responding to requests
- Feedback
- Provision of our online services and user experience
- Information technology infrastructure

Relevant legal bases

The following is an overview of the legal basis of the GDPR based on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

Contractual performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO)

Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request.- Registered interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary for the legitimate interests of the controller or a third party unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular concerning the establishment, implementation, or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Face Data Collection and Usage for Identity Verification

In our commitment to uphold the highest standards of user privacy and data security, we meticulously delineate our practices regarding the collection, use, disclosure, and retention of facial data obtained for identity verification purposes. Our application employs Amazon Web Services (AWS) Recognition for the sole purpose of identity verification, a process which necessitates a photograph of the user's face. Please be assured that this process is designed to respect user privacy in the following manner:

Data Collection: Our application does not collect or store face data within its own systems. When a user submits a photo for identity verification, this photo is transmitted directly to AWS Recognition without any duplication or retention on our end.

Data Usage: The photo provided by the user is exclusively used for the intended function of verifying the identity of the individual. We do not exploit this photo for any ancillary purposes, nor do we extract any additional data from this process.

Data Disclosure: There is a firm policy against sharing the submitted photo or any facial data derived from it with third parties. The integrity of our users' personal data is paramount, and as such, we ensure there are stringent controls against unauthorized disclosure.

Data Retention: We adhere to a strict policy of not retaining face data after the verification process. Once the photograph is forwarded to AWS Recognition and the necessary verification is complete, we ensure that the photo is not saved, stored, or otherwise retained in any of our systems or on any external storage devices.

Data Security: We employ robust security measures to safeguard the transmission of the photo to AWS Recognition, ensuring the data is encrypted in transit and handled with the utmost care.

Security measures

We take appropriate technical and organizational measures by the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, the input of, disclosure of, assurance of availability of, and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, and software as well as procedures following the principle of data protection, through technology design and data protection-friendly default settings.TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data. Data processing in third countriesIf we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done following the legal requirements.Subject to express consent or contractually or legally required transfer, we only process or allow the processing of data in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission:

Data deletion

The data processed by us will be deleted following the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.Our data protection notices may also contain further details on the retention and deletion of data, which have priority for the respective processing operations.

Provision of the online offer and web hostingWe process the users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).); security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Further notes on processing processes, procedures and services
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

Contact and request management

- Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g., collecting feedback via online form); providing our online service and user experience.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Further notes on processing processes, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).When contacting us (e.g. by contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out based on Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right to revoke consent: You have the right to revoke any consent given at any time.
- Right of access: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about such data, as well as further information and a copy of the data by the law.
- Right to rectification: You have the right, following the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, per the law, to request that data concerning you be erased without delay, or by the law, to request the restriction of the processing of the data.
- Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common, and machine-readable format, or to request that it be transferred to another controller, by the law.
- Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to complain with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Controller: "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, whether collecting, evaluating, storing, transmitting or erasing.