Privacy policy

(A) Who we are: We are FLEX APP LIMITED, a publishing company delivering apps for mobile devices. FLEX APP LIMITED is the controller of your personal information, and is responsible for your personal information. All references in this policy to "FLEX APP", "our", "us" or "we" refer to FLEX APP LIMITED, or our group companies, as appropriate.

(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts, so if you have any feedback on this privacy policy, please let us know using our contact details in section 8.

(C) Who this policy applies to: This policy applies to users of our apps and people who contact our customer support function.

(D) What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):
1. Collection of your personal information and how we use it:
2. Our legal basis for using your personal information;
3. How and why we share your personal information with others;
4. Children;
5. Where we may transfer your personal information;
6. Risks and how we keep your personal information secure;
7. Changes to this privacy policy; and
8.Further questions and how to make a complaint.

(E) Your rights to object: You have various rights in respect of our use of your personal information, as set out in section 5. Two of the fundamental rights to be aware of are that:
1. you may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
2. you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.

(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including downloading and using any of our apps, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

1. Collection of your personal information and how we use it

1.1 What personal information we collect about you
(a) Our apps collect the following information about you (and we use the information in the ways explained below):
(i) if you agree to receive personalized ads, data about your general location and the Identifier for Advertising (IDFA) of the device;
(ii) if you participate in any chat activity on our apps, we will collect your handle and any data that you share within your messages posted to that chat;
(b) If you contact our customer support function, we will collect your e-mail address (as well as any other information you include in your correspondence with us), including any updates to any of that information.

1.2 How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(a) to help us manage advertising and provide you with advertising and marketing via our apps that is relevant to you, both from us and from our third party partners, as further described in the 'Third party advertising' section below;
(b) to record your preferences in relation to advertising and marketing communications; and
(c) to receive and respond to customer support enquiries we receive from you.

1.3 Other uses of your personal information
(a) We also collect, use and store your personal information for the following additional reasons:
(i) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
(ii) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(iii) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(iv) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
(b) We will not use your personal information in any way that is incompatible with the purposes set out in this section 1. Please contact us using the details in section 10 if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

2. Legal basis for use of your personal information

2.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or
(b) you have provided us with your consent to do so. This applies in relation to the advertising and marketing materials delivered via our apps that are tailored to you and your preferences. You can control and withdraw your consent at any time on our apps.
(c) where (a) or (b) does not apply, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
(i) run, grow and develop our business (as well as the businesses of our group companies) including funding our business by use of advertising revenues;
(ii) and operate, maintain and improve our apps and our marketing optimisation efforts;

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 10.

3. How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

4. Children

4.1 You must be aged 16 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.

4.2 If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

4.3 Please contact us at flexapplimited@gmail.com if you are aware that we may have inadvertently collected personal information from a child below the age of 16.

5. Where we may transfer your personal information

5.1. Your personal information will be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or suppliers, including those located in the United States of America. Further details on to whom your personal information may be disclosed are set out in section 3.

5.2 When we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately.

5.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us via the e-mail address set out in section 10.

6. Risks and how we keep your personal information secure

6.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

6.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

6.3 Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

7. Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.

8. Further questions and how to make a complaint

8.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact flexapplimited@gmail.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

8.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of 15 October 2024.