Privacy Policy

  1. Introduction

    FrontApps, Czech Company located at U dálnice 815/6, Stodůlky, 155 00 Praha 5, Czech Republic, registered under the number 06541828 (Bloomy, the “Company”, "we", "us" or "our") respect your right to privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our APP (regardless of where you use it from) and tell you about your privacy rights and how the law protects you.

    Please also use the Definitions section 13 to understand the meaning of some of the terms used in this Privacy Policy.

  2. Important information
    1. Purpose of this Privacy Policy

      This Privacy Policy aims to give you information on how we collect and process your personal data through your use of our APP, including any data you may provide through the APP when you creating Account.

      This APP is not intended for children and we do not knowingly collect data relating to children. Our Services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our APP and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the Service or contact us.

      It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

      This version was last updated on May 27, 2019.

    2. Controller

      We are the data controller and responsible for your personal data.

      We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

    3. Contacting us

      Our full contact details are:
      U dálnice 815/6, Stodůlky, 155 00 Praha 5, Czech Republic

    4. The Data Protection Legislation

      On 25th May 2018 Regulation 2016/678 of the European Union on the protection of personal data (“GDPR”) came into force and we respect and follow this regulation in relation to the European Union residents as well in relation to other users (with some limitations depending on the user’s residence) for the reason that GDPR is the best practice for the purpose of data protection.

      It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

      We waive any liability and responsibility in relation to the fake or false data provided by the users.

    5. Third-party links

      This APP may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and are not responsible for their privacy statements. When you 2leave our APP, we encourage you to read the privacy policy of every website, plug-in and application you visit.

  3. The data usually collecting from the User

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may automatically collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

    Contact Data includes address, email address and telephone numbers.

    Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this APP.

    Usage Data includes information about how you use our APP.

    Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    We do not collect Financial Data including payment card details, because all transactions are proceeding through appropriate application platform (iTunes or Google Play). We would like to pay your attention that providing with any details of your credit (debit) cards within your profile data or messages is strongly not recommended. We do not have any liability and responsibility if you provide such information voluntary within your Account and/or Content.

    We might collect some Transaction Data including details about payments from you if such data is provided by appropriate application platform (iTunes or Google Play).

    We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), but we do not have any liability and responsibility if you provide such information voluntary within your Account and/or Content.

    If you fail to provide with personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel the Services you have with us but we will notify you if this is the case at the time.

    Your duty to inform us about changes

    It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

  4. The process of data collection

    We use different methods to collect data from and about you including through:

    Direct interactions. You may give us your Identity, Contact and Financial Data as part of our requirements by providing such information and completing profile.

    This includes personal data you provide when you:

    • create an Account on our APP;
    • enter to our APP through your current account in social networks;
    • subscribe to our service or publications; or
    • give us some feedback.

    Automated technologies or interactions. As you interact with our APP, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We might collect this personal data by using cookies and other similar technologies.

    Third parties or publicly available sources. We may receive personal data about you from various third parties.

    Data Protection Principles

    We will ensure that the personal information we hold about you is:

    • used lawfully, fairly and in a transparent way;
    • collected only for specified and legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
    • adequate, relevant and limited to what is necessary in relation to the purposes we have provided you about;
    • accurate and kept up to date;
    • not kept in a form which permits your identification for longer than necessary and kept only as long as necessary for the purposes we have provided you about;
    • kept securely; and
    • not transferred to another country without appropriate safeguards being in place.
  5. Using of personal data

    We will only use your personal data in accordance with Data Protection Legislation and the Data Protection Principals. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract, we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    Purposes of use of personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

    Purpose for which data is used Data Legal basis
    To provide you with our Services Name, email address, date of birth, location Contractual necessity
    To facilitate networking opportunities on our APP Optional information that you choose to provide in your profile, which may include information about your sexual preferences, religion, ethnic background, photos etc. Consent
    To verify your identity and prevent fraud and to ensure the safety and security of users Phone number Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the APP
    To serve targeted advertisements to users of our APP Demographic and location information Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue
    To send you marketing information about our offers and services Email address Legitimate interests – it is in our legitimate interests to promote our products and Services
    To enable users to create their Bloomy profile and log in to the app via Facebook Data from Facebook, including email address, name and profile picture, date of birth, friends who use the app, pages liked, location and photos Legitimate interests – it is in our legitimate interests to promote our products and services
    To show “nearby” location information to you and other users of the APP Wifi access points and location data when you use the mobile app Consent
    To provide the lookalikes function Photos and faceprint Legitimate interests – it is in our legitimate interests to provide this functionality
    To carry out analysis to help us improve the APP Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms Legitimate interests – it is in our interests to analyze the way in which users are accessing and using our services so that we can further develop the APP and improve the Services
    To fill Bloomy advertising content attracting new users Photos, faceprint and videos Consent
    To respond to correspondence and queries that you submit to us Email address and IP address Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to users and troubleshoot problems


    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    Opting out

    You can ask us to stop sending you marketing messages at any time by contacting us at any time.

    Change of purpose

    We will only use your personal data for the purposes for which we collected.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

  6. Disclosures of personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table:

    • liaising with regulators;
    • liaising with third party service providers (which may be providing other services, e.g. transaction service providers, advertisers);
    • liaising with any individual person and/or entity to which we have outsourced certain functions;
    • liaising with our legal advisors in respect of the services being provided to you by us.
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  8. Data retention

    The period of use of personal data

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    Usually we keep your personal information only as long as we need it for business purposes (as set out above) and as permitted by applicable law.

    In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

    • we must keep it to comply with applicable law (for instance, some "traffic data" is kept for one year to comply with statutory data retention obligations);
    • we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms and Conditions, Privacy Policy and other similar consents are kept for five years);
    • there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
    • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
  9. User’s legal rights

    You have certain rights in relation to your personal data as summarised here:

    • Right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with the information in this Privacy Policy;
    • Right to withdraw consent – where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time;
    • Right of access – you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
    • Correcting information – where we hold information about you that is inaccurate or incomplete, you have the right to ask us to rectify or complete it;
    • Right to be erased – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
    • Right to restrict processing – in certain circumstances you have the right to restrict some processing of your personal information, which means that you can ask us to limit what we do with it. For example, you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
    • Right to object to processing – you can object to us processing your personal information in certain circumstances, including where we are using it for the purpose of the Company’s legitimate business interests;
    • Right to data portability – you have the right to obtain from us and re-use your personal data for your own purposes. This only applies, however, where the processing is carried out by automated means, to personal data that you have provided to us yourself (not any other information) and where the processing is based on your consent or for the performance of a contract;
    • Right to complain – you are able to submit a complaint to authorities about any matter concerning your personal information, using the details below. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.

    The implementation of your legal right is subject to section 11 below and relevant procedure, i.e. contacting us you shall provide us with written request signed by you and containing clear information about you, the data, the right in relation to the personal data.

  10. Subject Access Requests

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may refuse to comply with your request in circumstances where your request is clearly unfounded, repetitive or excessive.

  11. Information that might be requested from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  12. Time limit to respond

    We try to respond to all legitimate requests as soon as reasonably practicable and, in any event, within 30 days of receipt of the request.

  13. Definitions

    data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

    data subjects for the purpose of this policy include all living individuals about whom we hold personal data. All data subjects have legal rights in relation to their personal information.

    personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.

    data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed.

    data users are those of our employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.

    data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.

    processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

    sensitive personal data and/or special categories of personal data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.

    Other definitions in this Privacy Policy that are not directly defined in the text of this document, shall be treated with the Section 1 Definitions of Bloomy Terms and Conditions at