Privacy Policy
Effective Date: [14-October-2024]
At Flitchr, your privacy is of utmost importance. This Privacy Policy outlines how we collect, use, and protect your personal data when you use the Flitchr app.
We believe that contacts are of your most valuable assets, and our services have been designed to protect it and empower you as its gatekeeper. Flitchr was designed to give you ownership and control of your contacts, and both our Terms and Conditions and our Privacy Policy have been designed to protect your data and to be straightforward and easy to understand.
In short: We never resell personal information about you or your contacts or share it unless necessary for the provision of the service.
Your data belongs to you, and you will always be able to delete your data from our systems. Protection of your data is our top priority, and we take significant measures to keep it safe and secure. This Privacy Policy describes how Flitchr may collect, use, store, and/or otherwise process personal data of the users of the Flitchr address book mobile application.
Any processing undertaken in this context shall be in compliance with the provisions of the General Data Protection Regulation (GDPR) and the UAE’s Federal Law No. 45 of 2021 concerning the Protection of Personal Data (PDPL).
This Privacy Policy does not concern the processing of the personal data of Third-Party Contacts of the users, which they provide when they use the Application. Flitchr and the user acknowledge and agree that with respect to the processing of such Third-Party Contact Data, as defined below, the user is the Data Controller, and Flitchr is a Data Processor acting pursuant to the terms of the relevant Flitchr data Processing Agreement.
References in this policy to “we”, “us”, and “our” are references to Flitchr. References to “you” and “your” are to the users.
Definitions
Application
The Flitchr app.
Flitchr
Refers to Flitchr, which provides the hardware or software tool by which personal data is collected.
Personal Data (or Data)
Any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
In the context of the services provided by Flitchr via the Application, Personal Data refers to data relating solely to the User/Users, as set out in the Types of Data Collected paragraph below.
Usage Data
Information collected automatically from Flitchr (or third-party service providers retained by Flitchr), as set out in detail in the Types of Data Collected paragraph below.
User/Users
The individual(s) downloading and using the Flitchr application.
User Data
Personal Data relating solely to the User, as set out in the Types of Data Collected paragraph below.
Data Subject
The natural person to whom the personal data relates. In the context of the services provided by Flitchr via the Application, Data Subject refers to User/Users.
Data Processor (or Data Supervisor)
The natural person, legal person, public administration, or any other body, association, or organization authorized by the Data Controller to process the personal data.
Data Controller
The natural person, legal person, public administration, or any other body, association, or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes and methods of processing of personal data and the means used, including the security measures concerning the operation and use of Flitchr.
Cookie
A small piece of data stored on the User’s device.
Third-Party Contact Data
Data other than User Data that is provided through the Flitchr app functionalities by the User to Flitchr that concerns persons other than the User and may include contact names, phone numbers, emails, and job titles.
Data Controller
With respect to the processing of personal data of the Users, Flitchr acts as a Data Controller. Our contact details are set out below:
Flitchr
[Dubai Silicon Oasis]
[Dubai], United Arab Emirates
Types of Data Collected
Flitchr collects your Personal Data when you download the Application and create an account with us, or automatically when using the Application.
Flitchr may collect the following types of information relating to Users, which also include Personal Data:
• Full name and email address of a User: whenever a User communicates with Flitchr with an inquiry, for support, or for changing their subscription plan.
• User profile data: Information about the User such as name, contact details, country, address, profile photograph, social account links, and job information.
• Usage Data: Information collected automatically by Flitchr (or third-party service providers retained by Flitchr), which can include the unique device identifier, the time of server requests, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application), and the details about the path followed within the Application with special reference to the sequence of pages visited.
• Cookies: Use of cookies or other tracking tools by Flitchr or third-party service providers retained by Flitchr.
We use cookies or other tracking tools to provide and operate the Application. Failure to provide these cookies may make it impossible for us to provide the Application.
Apart from cookies that are strictly necessary for providing the Application, and for which your consent is not required, we may also use cookies for improving our services, troubleshooting, as well as remembering your preferences for customization purposes. In such cases, we will request your explicit consent.
• User Account Data: Anonymous information about the settings chosen by you and any plans or subscriptions you have purchased (no credit card details are held by Flitchr).
Mode and Place of Processing the Data
Methods of Processing
Data is processed properly, and appropriate security measures are undertaken to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.
The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
In addition to Flitchr, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Processors or by potential purchasers or assignees of the Flitchr business.
We may share some of the Data with subsidiaries, joint ventures, or other companies under a common control (“Affiliates”). If another company acquires our company, business, or our assets, that company will possess the Data collected by us and will assume the rights and obligations regarding the Data as described in this Privacy Policy.
Place
The data is processed at the operating offices of Flitchr and in any other places where the parties involved with the processing are located. For further information, please contact Flitchr.
Transfers of data to countries outside the UAE may take place as part of the services described in this Privacy Policy. Any such transfers will be undertaken in compliance with the general principles on transfers, as set out in the PDPL and applicable international data protection regulations.
Retention Time
The data is kept for the time necessary to provide the service requested by the User, or as stated by the purposes outlined in this document. The User can always request that Flitchr corrects, suspends, or removes the data.
The Legal Bases for the Use of the Collected Data
The Data concerning you as a User is collected to allow Flitchr to provide its services via the Application.
We may also process your Personal Data where it is necessary for compliance with a legal obligation to which we are subject, for example, if we are required by law to disclose certain Data to public authorities.
Finally, it may be necessary for us to process your Personal Data for the purposes of legitimate interests pursued by us and where such interests are overridden by the interests or fundamental rights and freedoms of Users. For example, your Personal Data may be used for legal purposes in court proceedings or in the stages leading to possible legal action arising from improper use of the Application or the related services.
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