Privacy Policy
Last updated 3 October 2026
This policy covers the Frasero mobile app and this website. Who is responsible for the information described here – the data controller, in European terms – is SwagEazy LLC, d/b/a KDV Labs, of 1755 Broadway Front 3 PMB 1245, New York, NY 10019, United States, reachable at info@frasero.com.
The short version
- There is no sign-up. The app creates an anonymous account for your installation, not linked to your name or your email.
- We collect what we need to run the app, fix our content, answer you, and keep the app working – nothing more.
- We do not run ads, we do not track you across other apps or websites, and we do not sell or share personal information.
- You can delete your data from inside the app, or by email. Here is how.
1. Your anonymous account
Frasero has no sign-up, no password, and no social login. The first time the app runs, it creates an anonymous account with a random identifier, so that your progress can be backed up. The identifier is not linked to your name, your email address, or your device's advertising ID. It can become linked to you if you send it to us or write to us from an email address.
It is still personal data under the GDPR and similar laws, and we treat it that way. After a reinstall the app may start with a new account; any old records stay on our side until you delete them or they expire under section 6.
2. What we collect
| Category | What it covers | When |
|---|---|---|
| Identifiers | Your anonymous account identifier | First launch |
| App activity | Your practice progress and settings, and a record of which version of our Terms and this policy you accepted | As you use the app |
| Content you send us | Reports about exercises or lessons, and messages, with the app details needed to act on them | Only when you send one |
| Diagnostics | Crash and performance data: device and system details, the error, and an approximate, city-level location derived from your IP address | On errors, and on a sample of sessions |
| Contact details | Your email address, and a name if you choose to give one | Only if you join the waitlist or email us |
| Technical data | Request logs and a one-way hash of your IP address, used to keep our services secure | When you use the app or this website |
We do not ask for sensitive information – health, precise location, beliefs, and the like. Please do not put any in a report or a message; if you do, we delete it when we see it.
3. Why we use it, and on what legal basis
| Purpose | Categories | Legal basis (UK/EU GDPR) |
|---|---|---|
| Run the app and back up your progress | Identifiers, app activity | Performance of our contract with you (Art. 6(1)(b)) |
| Keep a record that you accepted our Terms | Identifiers, app activity | Legitimate interests – showing what you agreed to (Art. 6(1)(f)) |
| Fix our content and answer you | Content you send us, contact details | Contract, and legitimate interests in correcting content and supporting users (Art. 6(1)(b), (f)) |
| Keep the app working and secure | Diagnostics, technical data | Legitimate interests – diagnosing faults and preventing abuse (Art. 6(1)(f)) |
| Tell you when Frasero launches | Contact details | Your consent (Art. 6(1)(a)), which you can withdraw at any time |
| Comply with the law and defend claims | Whatever is relevant | Legal obligation (Art. 6(1)(c)) and legitimate interests |
4. Who helps us run Frasero
We use service providers to run Frasero. They process data only on our instructions, under agreements that require them to protect it at least as well as this policy does, and they may not use it for their own purposes.
| Type of provider | What it does | Where |
|---|---|---|
| Cloud hosting and database provider | Runs the anonymous accounts, stores backups and the content you send us, hosts this website | United States and other regions |
| Crash-reporting service | Receives and stores diagnostics | United States |
| App store operators | Distribute the app and confirm that requests come from the genuine app | United States |
| Messaging service | Delivers internal notifications to us, including copies of reports and messages | Outside the United States |
You can ask us which provider fills each role. Beyond these, we disclose information only if the law requires it, to establish or defend a legal claim, or to protect someone's safety. If Frasero is transferred to a new owner, information covered by this policy may go with it, still protected by this policy or one at least as protective, and we will say so first.
5. Where your data goes
We are based in the United States, and our providers process data there and elsewhere. If you are in the UK, the EEA, or Switzerland, your information is transferred out of your region under the safeguards in each provider's data processing terms – the European Commission's Standard Contractual Clauses and the UK addendum, or the EU–U.S. Data Privacy Framework, as applicable. You can ask us for a copy of the relevant safeguard.
6. How long we keep it
| Category | Kept for |
|---|---|
| Identifiers and app activity | Until you delete them, or 24 months after the app last syncs or you last accept our Terms |
| Content you send us | Up to 24 months |
| Diagnostics | Up to 90 days |
| Contact details: waitlist | Until 30 days after the launch announcement, or until you ask us to remove them |
| Contact details: emails to us | Up to 24 months after the conversation ends |
| Technical data | Up to 30 days |
Backups. We keep encrypted backups so we can recover from a failure, for up to one year. Deleted data stays in them until they expire, and if we ever restore one, we delete again the records of anyone who had already deleted their data. We may keep something longer only where the law requires it or to defend a legal claim.
7. What we do not do
- No advertising, no ad networks, and no advertising identifiers.
- No tracking across other apps or websites.
- No profiling for advertising, and no automated decisions with legal or similarly significant effects. The app tracks how you do on each exercise only to decide when to show it again.
- We do not sell or share personal information, as California and other U.S. state laws use those words, and we do not use it for cross-context behavioral advertising.
- No push notifications from our servers. The optional daily reminder is scheduled on your device.
8. Your rights
Everyone
Whatever law applies where you live, we will honor a request to see what we hold about you, correct it, or delete it.
UK, EEA, and Switzerland
You have the right to access your data, to have it corrected or erased, to restrict or object to our processing of it – including any processing we base on legitimate interests – to receive it in a portable form, and to withdraw consent at any time without affecting what we did before you withdrew it. You can complain to your national supervisory authority; in the UK, that is the Information Commissioner's Office.
California, and other U.S. states with privacy laws
Where a state privacy law applies to you, you have the right to know what we collect and why, to access it, to have it corrected or deleted, and to opt out of its sale, sharing, or use for targeted advertising or profiling. We do none of those last three, so there is nothing to opt out of. We will not treat you worse for exercising any right. You may use an authorized agent, and if we refuse a request you can ask us to reconsider by replying to our response. In the past year we disclosed identifiers and internet or device activity, for business purposes only, to the types of provider in section 4.
How to ask
Email info@frasero.com. Because the account is anonymous, we cannot look you up by name – send the identifier shown on the app's Contact screen, or write from the address you gave us. Without one of those we cannot find your records, and the law allows us to decline a request we cannot verify. We answer within 30 days, or 45 where a U.S. state law allows longer, and tell you if we need an extension.
9. Deleting your data
Open Profile in the app and choose Delete my data. It deletes your anonymous account and everything stored against it on our servers, and resets the app. A waitlist email is removed by email. The deletion pagecovers both routes and what stays.
10. Children
Frasero is not directed at children. You must be at least 16 to use it, as our Terms of Use say. We do not knowingly collect personal information from children under 13. If you believe a child has given us information, email us and we will delete it.
11. Security
Access to your data is restricted at the database level, the app's requests are checked to come from the genuine app, and traffic is encrypted in transit. No system is perfectly secure; if a breach affects you and the law requires notice, we will tell you and the relevant authority within the time the law allows.
12. Cookies and device storage
This website sets no cookies and uses no analytics or tracking, so there is nothing to consent to. The app stores your downloaded exercises, progress, and anonymous account on your device so practice works offline; that is storage the app needs to run, not tracking. Removing the app removes it, though some devices keep the anonymous sign-in after removal.
13. Do Not Track and Global Privacy Control
We do not sell or share personal information or track you across sites, whatever signal your browser sends, so these signals have nothing to switch off here.
14. Changes to this policy
If we change what we collect, why, or who helps us process it, we will update this page and the date at the top. If the change is material, we will give notice in the app or on this website before it takes effect.
15. Contact
SwagEazy LLC
1755 Broadway Front 3 PMB 1245
New York, NY 10019
United States
info@frasero.com