Flash Privacy Policy

Effective as of December 15, 2021.


Flash Labs GmbH, (“Flash”, “we”, “us”, or “our”) facilitates connections between our users (“users”) and our partner brands (“Partners”) through providing users with the ability to engage with, and purchase products from, our Partners without installing or downloading our Partners’ mobile applications through specially curated pop-up applications such as App Clips on iOS and Instant Apps on Android devices.

This Privacy Policy describes Flash’s privacy practices in connection with the joinflash.io website; Flash’s App Clips, Instant Apps, and the Flash native mobile application (each an “App,” and collectively, the “Apps”); and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

Flash may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

This Privacy Policy applies to the personal information we collect directly from our users and governs the interactions between us and our users. Your information may be collected, used and processed by one of our Partners. For more information on how your information may be collected, used and processed by our Partners please review the “Partner” portion of the “How We Share Your Personal Information” section of this Privacy Policy.

This Privacy Policy does not apply to how our Partners may use our users personal information. Please review the applicable Partner’s privacy policy to learn more about how it handles your personal information. We do not control how our Partners use your personal information.

Personal Information We Collect

Information you provide to us.

Personal information you provide to us through the Service or otherwise may include:

  • Transaction Data, such as information required to process an order you make through the Services.
  • Transaction data may include your first and last name, email and mailing addresses, and phone number.
  • Account Information, such as your username and password that you may set to establish an online account with us.
  • Content you choose to upload to the Service, such as text, along with the metadata associated with the files you upload.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic Information, such as your city, state, country of residence, postal code, and age.
  • Precise geolocation information, such as when you authorize our mobile application to access your location.
  • Financial information, such as financial account numbers or payment card information.
  • Transaction History, such as information about payments to and from you and other details of products or services you have purchased from our Partners.
  • Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
  • Marketing information, such as your preferences for receiving communications about our Service and future offerings, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
  • Information we obtain from social media platforms.
  • Information we obtain from other third parties.

We may maintain pages for the Service on social media platforms, such as Facebook, Twitter, Google, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to login to the Service via a third-party platform or social media network or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Apple ID and other information related to your account through Apple. You may also have the opportunity to provide us with additional information via the third-party platform or network, such as your email address. You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section.

We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly available sources and data providers.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. A SDK is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

Web browsers may offer users of our Service the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Service may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Referrals

Users of the Service may have the opportunity to refer contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or as described at the time of collection. To operate the Service we use your personal information to:

  • provide, operate and improve the Service;
  • provide information about our products and services;
  • establish and maintain your account on the Service;
  • facilitate your login to the Service via third-party identity and access management providers;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending you announcements, updates, and administrative messages;
  • understand your needs and interests, and personalize your experience with the Service and our communications;
  • provide support and maintenance for the Service; and to respond to your requests, questions and feedback.
  • For research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying your use of the Service.
  • To send you marketing and promotional communications. We may send you Flash-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
  • To send you recommendations. We may send you targeted recommendations for products and services based on your use of the Service.
  • To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
  • To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How We Share Your Personal Information

We may share your personal information with the following parties and as described in this Privacy Policy:

Service providers

We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Partners

Flash works with various Partners to make products and services available through its Apps. In order to provide you our Services, we may share your personal information, including your name, email address, phone number, and payment information collected and shared via Stripe, with specific Partners with whom you engage in the Apps. Please review the applicable Partner’s privacy policy to learn more about how it handles your personal information. We do not control how our Partners use your personal information.

Third-party platforms and social media networks

If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. For example, if you choose to use Apple Pay in connection with your use of the Services, such use is subject to Apple’s terms and conditions for use of Apple Pay, and the terms of the Flash Terms of Service. By using Apple Pay, you authorize us to share some of your personal information with Apple to allow it to facilitate transaction requests made through Apple Pay on iOS. Personal information shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. We do not control the third party’s use of your personal information.

Other users of the Service and the public

We may provide functionality that enables you to disclose personal information to other users of the Service or the public. You may be able to submit content to the Service, and we may display your name (or an, anonymized indicator) along with the content you submit. We may make available settings through the Service that enables you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information

If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of communications

Email

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at info@joinflash.io. You may continue to receive service-related and other non-marketing emails.

Text messages

If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. If you provide your phone number to us, Flash may also send you operational notifications by SMS or text (such as, security codes and password reminders). You may opt out of such SMS communications by texting “STOP” to the telephone number or short code we used to contact you.

Cookies & Browser Web Storage

We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. Privacy settings and location data. We may make available certain privacy settings on the Service. From time to time, Users of our Service may also have the choice whether to allow us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data. Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track.

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means. Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Service using the third party’s authentication service or otherwise connecting your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

Other Sites, Mobile Applications and Services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in Germany and may have service providers in other countries, and your personal information may be transferred to Germany or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Privacy Policy or privacy practices to info@joinflash.io. You may also write to us via postal mail at:

Flash Labs GmbH

Charlottenstraße 4

10969

Berlin, Germany