Flawnt Privacy Policy

Welcome to the Flawnt Privacy Policy (“Policy”)! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re enjoying the Flawnt mobile application (including the desktop version) (“App”), our websites and microsites (such as Flawnt.org) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your friends and contacts (“Users”). We may also need to share your information sometimes.

The App and Sites are global, and your information will be sent to and used in the United States and the UK regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

Who we are

The App and Sites are operated by the “Flawnt Group” (also referred to in this policy as “we” or “us”) which is Flawnt Limited which is the controller of personal information collected and processed through the Flawnt App and Sites.

The Flawnt Group has designated a Data Protection Officer and they can be reached by emailing info@flawnt.org or by post at the following address: Unit B, 12/F, Hang Seng Causeway Bay Building, 28 Yee Wo Street, Causeway Bay, H.K.

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

• Name;
• Username;
• Email address;
• Cell number;
• Gender identity;
• Date of birth;
• Sexual preference;
• Photographs;
• Location; and
• Login information for social media accounts that you connect to your Flawnt Account (this could include, for example, your Facebook and Instagram accounts). For more information about this, see “Linking other Accounts to Flawnt” in section 7 below.

Once you register, you will be able to review and change this information at any time just by logging in to Flawnt (other than your date of birth and location (which, if you have given Flawnt access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):

1. Identifiers, such as name and location;
2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
4. Commercial information, such as transaction information and purchase history;
5. Biometric information (not relevant here);
6. Internet or network activity information, such as browsing history and interactions with our Sites and App;
7. Geolocation data, such as mobile device location;
8. Audio, electronic, visual and similar information, such as photos and videos;
9. Professional or employment-related information, such as work history and prior employer;
10. Non-public education information; and
11. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Flawnt.

Profile Verification Information

For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number and, in some instances, we might also ask that you carry out at our questionnaire. We want to make sure you are not a robot! And we also want to avoid fake Flawnt accounts being created which can be used for malicious activities and cybercrime – they threaten the Flawnt network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue ‘verified’ badge to your profile).

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Flawnt uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Flawnt to contest the decision.

Please note that if your account is blocked for any reason, any account(s) that you have on other Flawnt Group platforms/applications, may also be blocked as part of our anti-spam and anti-fraud procedures.

Geolocation Information

If you have given Flawnt access to your location in your device settings, when you use your cell, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Flawnt access to your location, but wish to turn this off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Flawnt
2. Android — settings, location, Flawnt, permissions, location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address, for a number of purposes, as set out in this policy. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.

Links

We may keep track of how you interact with links available on Flawnt including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Messages

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

Flawnt Success Stories, Surveys and other Contributions

From time to time, we run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match on the App, we may contact you to ask if you would be happy to feature in advertising for Flawnt). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via info@flawnt.org.

When you Contact Customer Support

If you contact our Customer Support team via info@flawnt.org we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 6 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookies Policy.

2. USE OF YOUR INFORMATION.

Our main goal is to ensure your experience on Flawnt is an enjoyable one and you don’t end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

• offer you our services and features;
• contact you with information about the App (e.g., updates and new features);
• identify trends in how our Users use and interact with the App/Sites;
• personalize the App/Sites and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App/Sites;
• resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
• investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
• to send you information about the promotions and offers we have available – if you’ve signed up for our communications or otherwise told us it’s OK (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
• protect our Users and third parties from harm.

Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Flawnt to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

3. DISCLOSURE OF INFORMATION.

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

Flawnt does not sell your data and has not sold your personal data in the previous 12 months.

MORE INFORMATION ABOUT DISCLOSURES

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Flawnt shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

• Billing services – to allow customers to purchase paid features of our App
• Authentication services – to allow customers to authenticate their account
• Social media providers – to allow customers to create/connect their Flawnt account with their account(s) on such platforms (for example Facebook, Instagram or Spotify)
• Product improvement and market research – we use third party platforms and agencies to carry out customer surveys and market research to improve our products and services
• IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our community management software.)

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Sharing your personal data with Marketing Services Providers

We partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

• to exclude you from advertising campaigns aimed at finding new users, if you already have a Flawnt account;
• to show Flawnt adverts to users who have visited the Flawnt App/Sites but haven’t yet created a Flawnt account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive Flawnt advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with these Marketing Services Providers, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
• your estimated location (based on your IP address)
• age and gender
• data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App)
• a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters – this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy.

Some platforms require user consent before Flawnt is permitted to use data gained through the platform for advertising purposes and where this is the case, Flawnt will only use this data where the necessary consent has been obtained. Through your device’s privacy settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. If you would like more information about your choices and how you can stop your device identifiers being shared with third party advertisers, please contact us at info@flawnt.org. 

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

Sharing with Facebook

Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that Flawnt has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Data Policy. If you want more information relating to the nature of the arrangement we have in place with Facebook, please email info@flawnt.org.

This data referred to above can include actions that you take on our website such as your interactions with our Sites or other information collected from cookies or similar technologies including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook).

4. WHAT OTHERS MAY SEE ABOUT YOU.

We think our Users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.

When using the Flawnt App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain Flawnt badges to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Flawnt may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through the addition of badges to your profile, you are explicitly consenting to our processing of this information and making it public to other Users.

Your Flawnt profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook, Instagram or Spotify – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

Please also note that in certain countries (currently, South Korea only), Users are provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that Flawnt has no control over how users may then publish or use that information.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Flawnt account.

5. OUR POLICY TOWARDS AGE.

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App – sorry kids, we know Flawnt is cool, but you’ll have to come back when you’re old enough!

Flawnt does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

6. SECURITY.

Here at Flawnt, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
2. Please don’t share the password you use to access your Flawnt Account with anyone else!
3. Change your password periodically.

If you ever think someone has had access to your password or Account, please email us at info@flawnt.org. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

7. LINKING OTHER ACCOUNTS TO FLAWNT.

Using your social media details to sign in to Flawnt

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your Flawnt account and will be used to retrieve your Flawnt account.

We will then use this personal data to form your Flawnt account. If you remove the Flawnt app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Flawnt account using your Facebook or Apple ID (you must delete your Flawnt account entirely for us to no longer have access to this data).

Linking social media accounts to your Flawnt account

You may link your Flawnt account with your Instagram, Facebook or Spotify accounts. This allows you to share some information from those accounts directly to your Flawnt account (for example, Instagram photos, or your top Spotify artists).

We only receive the limited information that Instagram or Spotify permits to be transferred (as detailed by Instagram/Facebook/Spotify and agreed by you when you first connect your account from such platforms with your Flawnt account).

If you no longer want to link your Flawnt account to your Instagram, Facebook or Spotify account, please visit the settings in your Instagram, Facebook or Spotify account and follow the instructions to remove the Flawnt app access permissions. Please note that any information already added to your Flawnt account from those platforms will not be deleted unless you delete it within your Flawnt account as well.

8. YOUR CALIFORNIA PRIVACY RIGHTS.

For Users who are California residents, you have the following rights (in addition to those listed at section 9 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at info@flawnt.org.

From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.

9. YOUR RIGHTS.

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you want to exercise any of your rights listed above please email our Data Protection Officer at info@flawnt.org. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you live in a country or territory located in the European Union (EU) or European Economic Area (EEA), you may also get in touch with your local Data Protection Regulator. If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.

EU Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Flawnt has appointed Borlux Ltd as its GDPR representative in the EU. If you usually reside in an EU Member State you can contact Borlux Ltd regarding matters pertaining to the GDPR by:

Using the online request form at https://services.nathantrust.com/privacycontact

Postal address: 1st Floor, 6 Lapps Quay, Cork, Ireland

10. DATA LOCATIONS.

We want you to be able to access Flawnt wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, UK, EU, and (for Users located in Russia) Russia. The hardware is located in third-party data centers but is owned by the Flawnt Group. Data collected by Advertising Partners and other Service Providers may also be held outside the UK and the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place, please email info@flawnt.org.

11. DATA RETENTION AND DELETION.

We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law.

You may permanently delete your Account at any time (although we really hope you don’t!)

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 28 days, it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems, unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for accounting purposes);
2. we must keep it to evidence our compliance with applicable law;
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. 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.

Where Flawnt uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimize the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other User personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

To prevent abuse and/or misuse of Flawnt by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

Thanks for reading, we hope we didn’t drone on for too long!

12. CHANGES TO THIS POLICY.

As Flawnt evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at Flawnt.org/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Flawnt.

Effective date

This Privacy Policy was last updated November 15^th, 2021.