Privacy policy.
Last updated: October 16, 2025
1. WHO WE ARE AND SCOPE
This Privacy Policy explains how FRONTLINE App 1 Ltd ("Company", "we", "us") collects, uses, discloses, and protects Personal Data when you use our mobile applications (iOS now, Android later) and our website features (including email waitlist sign-up). FRONTLINE App 1 Ltd is the Data Controller for user Personal Data. FRONTLINE Ltd ("InfraCo") provides technology and acts as our Processor/technology provider. Website: frontlineupclose.com. Registered office: 3801‑C3.D037, 38th Floor, Tamouh, Addax Port Office Tower, Al Reem Island, Abu Dhabi, United Arab Emirates.
Contact: frontlinenews.app@gmail.com
Jurisdiction: Abu Dhabi Global Market (ADGM)
Data Protection Lead: Appointed (no formal DPO)
Third‑Party Sites, Platforms, and Embedded Services
When you access our services via a third‑party site or platform (e.g., Apple, Google) or interact with embedded players (e.g., YouTube), the third party may collect information under its own privacy policy. The information we collect is covered by this Policy; the information collected by the third party is subject to that third party’s practices. Privacy choices you set on a third‑party site or platform generally do not control our separate processing of information we collect directly through our services, and our choices do not control the third party’s processing.
Group Entities
FRONTLINE App 1 Ltd is the Controller. FRONTLINE Ltd provides technology and acts as our Processor under our instructions. FRONTLINE Ltd does not use your Personal Data for its own independent purposes.
2. ELIGIBILITY
Our services are for adults 18+ only. We do not knowingly collect Personal Data from anyone under 18. If we learn a minor has provided data, we will delete it.
3. PERSONAL DATA WE COLLECT
We collect only what we need to operate the service, comply with law, and improve safety and performance.
A. Account and Identity Data
- Sign-in tokens and identifiers from Apple and other sign-in providers (if/when enabled)
- Your chosen in-app username (may be a pseudonym)
B. Device and Technical Data
- IP address, device type, operating system/version, app version, language, time zone, and similar device metadata
- Push notification token (registered to enable remote push messaging)
C. Usage and Analytics Data (AWS-based)
- In-app events (e.g., app open, screen views, bookmarks), timestamps, and performance metrics
- Crash diagnostics and error logs (if crash reporting is enabled)
- Aggregated measurement to understand feature usage and stability
D. Purchase and Subscription Data
- Purchase confirmations and subscription status from Apple App Store (and Google Play when launched)
- We do not process or store your full payment card details; billing is handled by the App Stores
E. Communications and Feedback
- Content of messages or feedback you send us, and your email address if you contact us
- We may analyze feedback text using server-side AI tools to categorize, summarize, or prioritize responses
F. Website Waitlist
- Email address submitted to be notified about launches or updates (opt-in)
G. Geo-Blocking and Security Logs
- IP-based logs used to enforce geo-blocking and security (including enforcement of UAE and other restricted territory blocks)
H. Search and Preference Data
- Search queries you enter in the app and related filters; these may be linked to your account to improve relevance and quality, and are processed by our backend.
- On-device search history (stored locally; you can clear it where provided in-app).
I. Bookmarks and Saved Items
- Your bookmarks and saved items; at launch these may sync to your account for cross-device access. Local storage may also be used for performance and offline access.
J. Future Features (Not active at launch)
- User-generated content (e.g., comments) if/when enabled, and any information you choose to submit there
- Third-party advertising or ad-attribution SDKs are NOT used at launch. If introduced later, we will update this Policy, request required consents (e.g., iOS AppTrackingTransparency), and provide opt-out controls
- Public forums: If we enable public posting (e.g., comments), information you post will be visible to others and may be indexed or copied. Use caution when sharing Personal Data in public areas.
- Messaging: If we enable one-to-one or limited-group messaging, we may process content and associated metadata to operate the feature, prevent abuse, and comply with law.
4. PURPOSES AND LEGAL BASES
We process Personal Data only where a lawful basis under ADGM Data Protection Regulations (DPR) applies:
A. Contract Necessity
- Create and manage your account; provide core app features; deliver paid subscriptions; troubleshoot and support
B. Legitimate Interests (balanced against your rights)
- Ensure app and service security; prevent fraud and abuse; measure and improve performance and reliability; non-intrusive product analytics and crash diagnostics (AWS-based); internal reporting; sanctions and export control screening
- Provide aggregated or de-identified usage insights to the featured artist and their professional management to help understand audience engagement; we do not share identifiable usage data under this basis without your consent
- Protect the rights, property, and safety of us, users, and third parties; detect, investigate, and prevent policy violations or unlawful activity
C. Legal Obligations
- Comply with tax, accounting, corporate, media, consumer protection, sanctions, and export control laws; respond to lawful requests
D. Consent
- Website waitlist emails and any direct marketing communications
- Push notifications as required by your platform; you can withdraw at any time in device settings
- Any future ad-attribution or tracking that requires opt-in (e.g., iOS ATT) will be based on consent
- Sharing your name and contact details with the featured artist and their professional management so they can send you their own communications, where you have opted in; you can withdraw consent at any time
We do not engage in automated decision-making that produces legal or similarly significant effects about you.
5. PUSH NOTIFICATIONS
We ask your device for permission before sending push notifications. We register your device token to enable remote push notifications via our provider (e.g., AWS Pinpoint). You can change your notification preferences at any time in your device settings. Notifications may include service updates or (where required by law, with consent) marketing messages about our own products and features.
6. COOKIES AND ONLINE IDENTIFIERS
App: We do not use third-party advertising cookies or SDKs at launch. We may use device identifiers and similar technologies (including SDKs, APIs, tags, and pixels) for essential functions and AWS-based analytics and push messaging.
Embedded Content: When you play embedded content such as YouTube videos inside the app, YouTube may collect device and usage data via its embedded player under its own privacy policy.
Website: If cookies are used, they are primarily for essential functions and basic analytics. We do not use third-party advertising cookies at launch. You can control cookies via your browser settings. We will update this Policy before introducing non-essential cookies that require consent.
Do Not Track and Global Privacy Control
Browsers may transmit “Do Not Track” (DNT) signals; there is no industry consensus on how to respond and we do not respond to DNT signals. We honor Global Privacy Control (GPC) signals to the extent required by applicable law for sale/sharing and targeted advertising. We do not sell or share Personal Data at launch.
7. AI USE
We use server-side AI tools to analyze user feedback that you submit (e.g., to categorize or summarize). We do not use AI to make decisions that have legal or similarly significant effects about you, and we do not use AI to profile you for cross-context behavioral advertising.
8. DISCLOSURES TO PROCESSORS AND THIRD PARTIES
We share Personal Data only with service providers acting on our instructions or where necessary to provide the service or comply with law:
- Cloud infrastructure, storage, analytics, and logging (AWS and related AWS services)
- Error/crash reporting (AWS-based tooling)
- Email delivery/support tools (for communications and waitlist)
- Content/data providers accessed by or embedded in the app (e.g., YouTube, News APIs, Spotify). When you use embedded players, those providers may act as independent controllers under their own privacy policies.
- Featured artist and their professional management (with your consent for identifiable information such as your name and contact details; we may also share aggregated or de-identified usage insights). The featured artist/management typically act as independent controllers for their own processing and their privacy policies will apply.
- Professional advisers (legal, audit) under confidentiality
- Government, regulators, courts, and law enforcement when required by law
At launch we do not share Personal Data with third-party advertising networks and we do not use third-party ad-attribution SDKs. We do not sell or "share" Personal Data for cross-context behavioral advertising.
De‑identified and Aggregated Data
We may create and use de‑identified and aggregated data for analytics, reporting, and to provide non‑identifying audience insights (including to the featured artist/management). We implement safeguards and commit not to attempt to re‑identify such data.
A current list of our processors and sub-processors is available upon request.
YouTube API Services (backend use only): Our backend uses YouTube Data API Services to fetch public content and metadata for features such as search and embedding. We do not provide user accounts or user Personal Data to the YouTube Data API. Your interactions with the YouTube embedded player are governed by the YouTube Terms of Service and Google Privacy Policy. You can learn more at https://www.youtube.com/t/terms and https://policies.google.com/privacy.
9. INTERNATIONAL TRANSFERS
We operate globally using cloud providers outside your home country. Our hosting and processing occur in non-UAE regions. Where transfers are made to jurisdictions not deemed adequate under ADGM DPR (for example, the United States), we rely on appropriate safeguards, including ADGM Standard Contractual Clauses (Schedules 1 and 2) with counterparties where applicable, plus technical and organizational measures.
If we share data with the featured artist or their professional management located outside an adequate jurisdiction, we will apply the same safeguards.
10. RETENTION
We keep Personal Data only as long as necessary for the purposes described or as required by law:
- Account data: retained while your account is active, then deleted or anonymized within 30 days after confirmed deletion
- Subscription and transaction records: retained for legal/tax obligations (typically 6–7 years)
- Security and geo-block logs: retained for up to 5 years to evidence compliance and for security
- Push notification tokens: retained while your account is active; removed when your device unregisters the token or upon account deletion
- Analytics and crash diagnostics: raw device-level analytics retained up to 13 months, then aggregated or anonymized
- Search history stored on-device: retained until you clear it or reinstall the app
- Server-processed search queries: retained as necessary to provide the service and for quality and security, then aggregated or anonymized
- Bookmarks and saved items: retained while your account is active; local copies are retained until you remove them or reinstall the app
- Website waitlist: retained until you unsubscribe or we fulfill the purpose, then deleted within 30 days
- Communications and feedback: retained as needed for support and quality (typically up to 24 months), unless legal needs require longer
11. YOUR CONTROLS AND CHOICES
Push Notifications: Manage in your device settings at any time.
Search History (on-device): Clear within the app where available.
Marketing Emails & Waitlist: Unsubscribe via email link or by contacting us.
Sharing with Featured Artist/Management: Withdraw your consent at any time by contacting us.
Account Deletion: Use the in-app path where available or email us; we will verify your identity.
Website Cookies: Use the “Manage Cookies” link on our website to set preferences for non-essential cookies (where deployed).
U.S. Opt-Outs: We do not “sell” or “share” personal data for cross-context behavioral advertising. We honor Global Privacy Control (GPC) signals to the extent required by law.
Appeals (U.S. states where applicable): If we deny a privacy request, you may appeal by emailing us with “Privacy Request Appeal” in the subject. We will respond within the period required by law.
Authorized Agents (U.S. where applicable): You may designate an agent to make requests on your behalf. We will require proof of authorization and identity verification.
12. YOUR RIGHTS
Subject to applicable law (including ADGM DPR and, where applicable, EU/UK and certain U.S. state laws), you may have rights to:
- Access your Personal Data and receive a copy
- Rectify inaccurate data
- Erase your data (right to deletion)
- Restrict processing
- Object to processing based on legitimate interests
- Data portability
- Withdraw consent at any time (does not affect prior processing)
To exercise rights: email frontlinenews.app@gmail.com. We may need to verify your identity. You also have the right to lodge a complaint with the ADGM Office of Data Protection or your local authority where applicable.
We aim to respond to valid requests within 30 days of receipt, extendable by up to two further months where necessary due to complexity or number of requests, as permitted by ADGM DPR.
Where an in-app account deletion feature is available, you may also request deletion from within the app; we will reflect the exact in-app path where applicable.
13. SECURITY
We implement technical and organizational measures appropriate to the risk, including encryption in transit and at rest, access controls, environment segregation, and logging. We minimize logs and avoid storing secrets or tokens in logs in production systems. No system is 100% secure; we cannot guarantee absolute security.
14. CHILDREN
We do not knowingly collect data from individuals under 18. If you believe a minor has provided data, contact us to request deletion.
15. MARKETING AND CROSS-PROMOTION
We may promote our own services within the app. We do not share your Personal Data with other FRONTLINE-branded companies for their independent marketing without your consent. Website waitlist emails are sent only with your consent, and you may unsubscribe at any time.
With your consent, we may share your name and contact details with the featured artist and their professional management so they can send you their own communications. You can withdraw your consent with us at any time; if we have already shared your details based on your consent, you may need to contact the artist/management directly to stop their communications.
16. THIRD-PARTY CONTENT AND LINKS
Our app may link to or embed third-party services (e.g., YouTube, news sources, music platforms). When you interact with those services (including embedded players), their privacy policies apply. We do not control their practices.
Video Privacy (U.S.)
We do not disclose your video viewing records to third parties for their own marketing. If we later introduce features that would involve sharing such information beyond our processors, we will obtain any consents required by applicable law before doing so.
17. BUSINESS TRANSFERS
If we are involved in a merger, acquisition, restructuring, or asset sale, your Personal Data may be transferred to the successor entity, subject to this Privacy Policy and applicable law. We will provide notice where required by law.
18. CHANGES TO THIS POLICY
We may update this Policy from time to time. We will indicate the "Last updated" date and, where required, provide additional notice. Continued use of the services after an update means you acknowledge the changes.
19. GEO-BLOCKING AND RESTRICTED TERRITORIES
We may restrict access to the app in certain jurisdictions for legal, compliance, or business reasons (including the UAE and other territories as updated over time). We enforce these restrictions through technical measures (e.g., IP-based controls). Attempting to circumvent geo-blocks (e.g., via VPN) may result in access being limited or terminated.
20. U.S. STATE PRIVACY NOTICE
This supplement applies to residents of California and other U.S. states with privacy laws. Categories collected in the last 12 months include: identifiers (e.g., device ID, IP address), internet/network activity (in-app events, logs), approximate geolocation (IP-based), commercial information (subscription status), and inferences (none at launch). Sensitive personal information is not collected at launch.
Purposes: As described in “Purposes and Legal Bases.”
Disclosure: We disclose Personal Data to processors/service providers as described in “Disclosures.”
Sale/Sharing/Targeted Advertising: We do not “sell” or “share” Personal Data (as defined by state law) and we do not process Personal Data for targeted advertising at launch.
Your Rights: Depending on your state, you may have rights to access, delete, correct, obtain a portable copy, and to opt out of sale/sharing/targeted advertising (not applicable at launch), without discrimination. You may also designate an authorized agent and appeal a denied request. Submit requests to frontlinenews.app@gmail.com. We will verify identity before fulfilling requests.
21. DMCA AND LEGAL REQUESTS
If you submit a copyright notice, counter-notice, or other legal request, we process the Personal Data contained in your submission (e.g., name, contact details, statements) to comply with law, manage claims, and operate our services. Where required, we may forward your notice (including contact information) to the user who provided the material. We retain related records as required by law and our retention schedule. See our DMCA Policy for details.
22. INFORMATION FROM OTHER SOURCES
We may receive information about you from service providers and partners, such as app stores (e.g., subscription status confirmations), sign-in providers (e.g., authentication tokens), fraud and security vendors, and analytics providers. We use this information to operate our services, prevent abuse, and comply with law. We do not use these sources for third-party targeted advertising at launch.
23. SENSITIVE DATA AND PRECISE LOCATION
We do not intentionally collect special/sensitive categories of Personal Data (e.g., health, biometrics) or precise geolocation at launch. Please do not include sensitive data in feedback or public posts. If we introduce features involving sensitive data or precise location, we will provide clear notices and, where required, obtain consent.
24. CONTACT
Controller: FRONTLINE App 1 Ltd
Processor/Technology Provider: FRONTLINE Ltd
Email: frontlinenews.app@gmail.com
Website: frontlineupclose.com
Registered office: 3801‑C3.D037, 38th Floor, Tamouh, Addax Port Office Tower, Al Reem Island, Abu Dhabi, United Arab Emirates
If you have questions or requests about this Policy or our data practices, please contact us.