Privacy Policy

Your privacy is important to us. It is the policy of FlexiApps SARL to respect your privacy and comply with any applicable laws and regulations regarding personal information we may collect about you, including on our website, https://flexiapps.net, and other sites we own and operate.

Personal information is any information about you that can be used to identify you. This includes information about you as an individual (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In case our site contains links to third-party sites and services, please note that these sites and services have their own privacy policies. After following a link to third-party content, you should read their privacy policy information regarding the collection and use of personal information. This privacy policy does not apply to your activities once you leave our site.

This policy is effective as of July 25, 2020.

Last Updated: February 19, 2024

Information We Collect

The information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you deliberately and actively provide to us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices when accessing our products and services.

Log Data

When you visit our website, our servers may automatically log standard data provided by your web browser. This may include your device’s Internet Protocol (IP) address, browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error occurred, and other technical information related to the issue. You may or may not be notified of such errors, even at the time they occur, or of their occurrence or nature.

Please note that while this information may not be personally identifiable by itself, it could be possible to combine it with other data to personally identify individuals.

Device Data

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

Device type Operating system Unique device identifiers Device settings Geolocation Data

The data we collect may depend on your device and software individual settings. We recommend checking your device manufacturer’s or software provider’s policies to understand what information they make available to us.

Personal Information

We may request personal information, for example, when you subscribe to our newsletter or when you contact us. This may include one or more of the following elements:

Name Email address Social media profiles Date of birth Phone number/mobile Home/mailing address

“Sensitive information” or “special categories of data” constitutes a subset of personal information that enjoys a higher level of protection. Examples of sensitive information include data regarding your racial or ethnic origin, political opinions, religion, membership in trade unions or other professional associations, philosophical beliefs, sexual orientation, sexual practices or your sexual life, criminal records, health information, or biometric data.

The types of sensitive information we might collect about you include:

Biometric information

We will not collect sensitive information about you without obtaining your prior consent, and we will only use or disclose your sensitive information to the extent permitted, required, or authorized by law.

User-Generated Content

We consider “user-generated content” to be materials (text, image, and/or video content) voluntarily provided by our users for the purpose of being published, processed, or used on our platform. All user-generated content is associated with the account or email address used to submit the materials.

Please note that any content you submit for the purpose of publication will be public after publication (and the subsequent review or validation process). Once published, it may be accessible to third parties not covered by this privacy policy.

Transaction Data

Transaction data refers to data that accumulates over the normal operation of our platform. This may include transaction records, stored files, user profiles, analytical data, and other types of information, created or generated, as users interact with our services.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason to do so. In this case, we only collect personal information reasonably necessary to provide you with our services.

Collection and Use of Information

We may collect personal information from you when you perform any of the following actions on our website:

Account registration Subscription purchase Signing up to receive updates from us via email or on social media channels Using a mobile device or web browser to access our content Contacting us via email, social media, or similar technologies Mention from our side on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be processed further in a way that is incompatible with these purposes:

Providing the basic features and services of our platform Allowing you to customize or personalize your experience on our website Delivering products and/or services Contacting and communicating with you For analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms Enabling you to access and use our website, associated applications, and associated social media platforms Attributing any content (e.g., posts and comments) you submit and we publish on our website For technical assessment, including to operate and improve our application, associated applications, and associated social media platforms

We may combine voluntarily provided information and automatically collected information with general information or research data we receive from other trustworthy sources. For example, if you provide us with your location, we may combine that with general information about currency and language to offer you an enhanced experience on our site and services.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it in commercially acceptable ways to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

While we do our best to protect the personal information you provide us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for choosing any password and overall security, ensuring the security of your own information within the limits of our services. For example, make sure that all passwords associated with access to your personal information and accounts are secure and confidential.

Retention Period of Your Personal Information

We retain your personal information only for the period necessary. This period may depend on the purpose for which we use your information, in accordance with this privacy policy. For example, if you provided us with personal information for the purpose of creating an account with us, we may retain this information for as long as your account exists in our system. If your personal information is no longer needed for this purpose, we will delete or anonymize the details identifying you.

However, if necessary, we may retain your personal information to comply with a legal, accounting, or reporting obligation, or for archiving in the public interest, scientific or historical research purposes, or statistical purposes.

Children’s Privacy

We do not target any of our products or services directly to children under the age of 13, and we do not knowingly collect personal information about children under the age of 13.

Disclosure of personal information to third parties

We may disclose personal information to:

  • a parent company, subsidiary, or affiliate of our company
  • third-party service providers to enable them to provide their services, including (but not limited to) computer services, data storage, hosting and servers, analytical services, error recorders, collection agencies, maintenance or troubleshooting providers, marketing providers, professional advisors, and payment system operators
  • our employees, contractors, and/or related entities
  • our existing or potential business partners or agents
  • credit rating agencies, courts, and regulatory authorities, in case you fail to pay for the goods or services we provided
  • courts, tribunals, regulatory authorities, and law enforcement agents, as required by law, in connection with actual or potential legal proceedings, or to establish, exercise, or defend our legal rights
  • third parties, including agents or subcontractors, who assist us in providing information, products, services, or direct marketing to you
  • third parties for the collection and processing of data
  • an entity that acquires, or to which we transfer, all or a substantial part of our assets and business

The third parties we currently use include:

  • Google
  • Analytics
  • Facebook
  • Pixel
  • Firebase
  • Mailgun
  • Paypal
  • Stripe
  • CMI

International transfers of personal information

The personal information we collect is stored and/or processed in Germany or wherever we, our partners, affiliates, and third-party providers have facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you originally provided the information. If we transfer your personal information to third parties in other countries: (i) we will make these transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your rights and control of your personal information

Your choice: By providing personal information, you understand that we will collect, retain, use, and disclose your personal information in accordance with this privacy policy. You are not obligated to provide us with personal information; however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as stated in this privacy policy. If you are a third party providing personal information about someone else, you represent and warrant that you have the consent of that person to provide us with their personal information.

Permission marketing: If you have previously agreed to us using your personal information for direct marketing purposes, you can change your mind at any time by contacting us using the details below.

Access: You can request details about the personal information we hold about you.

Correction: If you believe the information we hold about you is inaccurate, outdated, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information deemed inaccurate, incomplete, misleading, or outdated.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is necessary to provide you with a specific service or offer (e.g., transaction data processing), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties, or providing you with a different level or quality of goods or services.

Download of personal information: We provide a way for you to download the personal information you have shared on our site. Please contact us for more information.

Notification of data breaches: We will comply with applicable laws in the event of a data breach.

Complaints: If you believe that we have violated a relevant data protection law and want to file a complaint, please contact us using the details below and provide all details of the alleged violation. We will promptly investigate your complaint and respond to you in writing, outlining the results of our investigation and the measures we will take to address your complaint. You also have the right to contact a regulatory body or data protection authority regarding your complaint.

Limits of our policy

Our website may contain links to external sites not operated by us. Please note that we have no control over the content and policies of these sites, and we cannot accept responsibility for their respective privacy practices.

Changes to this policy

At our discretion, we may modify our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here, at the same link through which you access this privacy policy.

If the changes are significant or if required by applicable law, we will contact you (based on your communication preferences with us) as well as all our registered users with the new details and links to the updated or modified policy.

If required by law, we will obtain your permission or give you the opportunity to give your consent or refuse, as applicable, to any new use of your personal information.

Additional disclosures for compliance with the General Data Protection Regulation (GDPR) (EU) Data Controller / Data Processor

The GDPR distinguishes between organizations processing personal information for their own purposes (called “data controllers”) and organizations processing personal information on behalf of other organizations (called “data processors”). We, FlexiApps SARL, located at the address provided in our Contact Us section, are a data controller regarding the personal information you provide to us.

Legal bases for processing your personal information

We will only collect and use your personal information when we have the legal right to do so. In these cases, we will collect and use your personal information lawfully, fairly, and transparently. If we request your consent to process your personal information and you are under 16 years of age, we will seek the consent of your parent or legal guardian to process your personal information for that specific purpose.

Our legal bases depend on the services you use and how you use them. This means we only collect and use your information on the following bases:

Consent from you

When you give us your consent to collect and use your personal information for specific purposes. You can withdraw your consent at any time using the means we provide; however, it will not affect the use of your information that has already occurred. You can consent to provide your email address for the purpose of receiving marketing emails from us. While you can unsubscribe at any time, we cannot recall emails that we have already sent. If you have further questions about how to withdraw your consent, feel free to contact us using the details provided in the Contact Us section of this privacy policy.

Performance of a contract or transaction

When you have entered into a contract or transaction with us, or to take steps before entering into a contract or transaction with you. For example, if you purchase a product, service, or subscription from us, we may need to use your personal and payment information to process and deliver your order.

Our legitimate interests

When we believe it is necessary for our legitimate interests, such as providing, operating, improving, and communicating our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with the law

In certain cases, we may have a legal obligation to use or retain your personal information. These cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have further questions about how we retain personal information to comply with the law, feel free to inquire using the contact details provided in the Contact Us section of this privacy policy.

International transfers outside the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries within the European Economic Area (EEA) to countries outside the EEA is protected by appropriate safeguards, such as using standard data protection clauses approved by the European Commission or the use of binding corporate rules or other legally accepted means.

Your rights and control of your personal information

Restriction: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been processed unlawfully; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are reviewing your objection to processing based on legitimate interests.

Objection to processing: You have the right to object to the processing of your personal information that is based on our legitimate interests or the public interest. If this is done, we must provide compelling legitimate grounds for the processing that override your interests, rights, and freedoms in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. To the extent possible, we will provide this information in a CSV format or any other machine-readable format. You may also have the right to request that we transfer this personal information to a third party.

Deletion: You may have the right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will inform you of the impact of deletion on your use of our website or products and services. There may be exceptions to this right for specific legal reasons, which, if applicable, will be specified in response to your request. If you terminate or delete your account, we will delete your personal information within 90 days of the deletion of your account. Please note that search engines and similar third parties may still retain copies of your personal information that have been made public at least once, such as certain profile information and public comments, even after you have removed the information from our services or deactivated your account.

Contact us

For any questions or concerns regarding your privacy, you can contact us using the following details:

Customer Service: FlexiApps contact@flexiapps.net