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Flirtual AI (hereinafter “we”, “us”, “our” etc.) values the privacy of all of our users and has established this privacy policy (hereinafter the “Privacy Policy”) to show commitment to these rights and to safeguard your privacy. If you (hereinafter “you”, “yours”, etc.) use (i) our website (hereinafter the “Website”) or (ii) our apps, including mobile applications, downloadable products as well as pages operated by us on social media sites and other platforms, (points (i) and (ii) collectively the “Services” provided under the Terms of Use Agreement (‘Terms’)), then we urge you to read this Privacy Policy and become fully informed about how it affects your personal privacy. Please refer to this Privacy Policy to find out how to CONTACT US if you have any questions about the contents herein.
TABLE OF CONTENTS
2. WHEN YOU ACCEPT THIS PRIVACY POLICY
4. WHAT DATA WE COLLECT AND HOW
INFORMATION ABOUT HOW YOU USE OUR SERVICES
PERSONAL DATA WE COLLECT AUTOMATICALLY
PERSONAL DATA WE COLLECT USING COOKIES AND SIMILAR TECHNOLOGIES
5. HOW WE USE YOUR PERSONAL DATA
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
OUR SERVICE PROVIDERS AND STAFF
7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA
8. CHANGES TO YOUR PROFILE AND OPT-OUT FROM COMMUNICATION
Our Services are operated by Novi Limited (the “Data Controller”). Please find more details in the CONTACT US section down below.
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise YOUR LEGAL RIGHTS, please contact the DPO using the details set out in the CONTACT US section down below.
By using our Services, you are accepting the conditions set out in this Privacy Policy.
Persons under 18 years of age are not allowed to use our Website or any of our Services, as they are not targeted at persons under the age of 18. Any personal data we receive from users we believe to be aged 18 or under will be removed from our database.
If you believe that we have collected, used or disclosed personal data of a person under the age of 18 (or the age of majority in your jurisdiction), please contact our support team via the CONTACT US section down below so that we can take appropriate action.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
When you register, use or subscribe to our Services or take part in any interactive features of the Services (such as any communications with virtual companions, our promotions, quizzes, surveys, research or other services or features), we may collect a variety of information, including:
Contact Information such as your name (if any) and email address (“Contact Data”).
Sensitive Information in course of using our services such as race, ethnicity, sexual preferences and experiences, political affiliation, religious affiliation, union memberships you may provide through the use of our Services (your “Sensitive Personal Data”).
Other information such as birth date, password, and any other information you share during the use of our Services, including in course of playing scenarios (your “Extended Data”).
Information disclosed through communication with our support team. You may also provide us with other personal data when you communicate with us regarding our Services (your “Communications Data”);
Mandatory information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or to verify the personal data we have collected.
We may collect information about your participation and actions during your use of our Services. This may include information such as the pages you view, how you browse our platform. It can also include the various functions and features that you use.
Where there is any functionality on uploading media to our platform, like photo, video or voice recording, we may collect information about the content, such as the time, date and place, the media type or content was taken or uploaded (also known as metadata), and how you use them. In this case, we may also scan and analyze the content you provide to us using third party services for several purposes, including for anti-fraud purposes, for the assessment of whether the photos are consistent with our Terms, to help identify your interests and activities to help us provide better services for you.
We collect communications you send to us (such as email or push notifications), comments that you post on the pages we have on a third-party service, such as our Instagram, Twitter, Whatsapp, Facebook and other pages, as well as messages that you send us directly through those services (“Communication Data”). We may also collect and analyze any comments, photos, messages or other content of communications you and other users share on our Services.
When you access our Services, we and our third party partners automatically record information from your device and its software, in particular, we may collect:
data about your interaction with our Services and your communications with us. This is personal data we receive from devices (including mobile devices) you use when you access our Services. This personal data may include the following: device number, device ID or unique identifier, device type, unique device token, operating system, application crash-data, IP address, user agent, platform, Software Development Kit version, anonymous User ID, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), referrer url (Google Play Store), Google Advertiser ID, device model, manufacturer, OS version, in-app events, network status (WiFi/4G), login source, application use, age, gender, whether the profile is linked to Facebook/Google and their profile photo, notification status, internet navigation details (for example, how your mouse moves on a screen which tells us if you’re a bot or real person) registration date, credits bought, date of last payment and use of services (“Technical Data”);
Real location data, including physical location data from your mobile device including specific geographic locations through IP, GPS, Bluetooth, or WiFi signals (“Location Data”).
We use cookie technology on the Website as part of the statistical reporting. It contains personal data used by the Website to personalize your experience (e.g. rotating profiles on our home page) and to gather statistical data, such as which pages are visited, what is downloaded during your experience, the domain name and country of the internet provider that you have come from (e.g.‘aol’, or ‘umich.edu’), and addresses of those websites you have visited just before and after the Website. Nevertheless, we do not associate any of this personal data with you as an individual. Only an aggregate measure is taken. Cookie personal data allows us to follow your “clickstream” activity (i.e., how visitors navigate our Website as they move from page to page). It is important to note that cookies never capture your individual email address or any of your private personal data.
We also operate standard web server log files to assist in counting visitor numbers and analyzing our Service technical capability. This personal data is used to establish how many people use our Services, enable us to organize our Services for the best usability, make our Services suitable for your browser, and ensure that our Services are working at their full potential. Although we collect personal data on online traffic, we do not record personal data on particular visitors of our Services, which means that no personal data about you as an individual is retained or used. You are able to browse the Website without cookies by configuring your browser to reject all cookies, or to alert you when a cookie is sent. Since each browser is different, you should refer to the “Help” menu of your browser to learn how to change your cookie preferences.
Where you do not provide the personal data detailed in this Privacy Policy, you may not be able to use our Services. Please note that providing incorrect, outdated, or false information may result in our services not functioning properly or at all. To ensure the best experience, we encourage you to provide accurate and up-to-date data.
Generally, we may use your personal data based on the following legal grounds:
Where we need to perform the contract we are about to enter into or have entered into with you for the Services.
Where you have given consent for us to use your personal data and, where applicable, your Sensitive Personal Data to provide certain Services (you may withdraw your consent for some uses of the data at any time in your Profile or via CONTACT US section down below).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Unless specifically mentioned, we do not use your personal data for any other reason. We will never sell your personal data to a third party, and we will never give a third party access to your personal data, except as may be provided in our Terms, Refund and Cancellation Policy, this Privacy Policy or unless required to do so by law.
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. Please CONTACT US if you need details about the specific legal ground we are relying on to process your personal data where more than one legal ground has been set out in the table below.
| Purpose/Activity | Type of personal data | Legal grounds for processing personal data |
|---|---|---|
| Registration you with our services | (a) Profile Data, such as name (if any) (b) Contact Data such as email address, (c) Data from Social Media Sites (e.g., if you use Google to log-in to the Services), including any interests or other data imported from your Social Media Sites (d) Technical Data, such as device ID or IP Address, including timestamps (e) Extended Data |
(a) Performance of a contract with you (b) With your consent in the case of sensitive personal data in Extended Data |
Provision of the Services to you, including: (a) Maintaining a profile, answering questions, and providing information about yourself; (b) Analyzing your personal data to develop and improve Services and our products; (c) Allowing you to communicate with us; and (d) Enabling you to pay for the Services |
(a) Profile Data, such as name (if any) (b) Contact Data such as email address (c) Transaction Data, such as name, address, transaction ID, timestamps, email address, currency, and routing number (d) Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages (e) Analytics Data (f) Technical Data (g) Extended Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interest (for analytics data where we analyse your use of Services and compliance with our Terms and policies) |
Management of our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Communicating with you |
(a) Profile Data (b) Transaction Data (c) Contact Data (d) Communications Data (e) Photos (if any) (f) Extended Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
| Administration and protection of our business, our Services, contravention or unauthorized use of our Services and your personal data (including security, fraud, court proceedings, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Profile Data (b) Contact Data (c) Technical Data (d) Communications Data (e) Extended Data (f) Any personal data related to the user in communication with support team or companion |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, cybersecurity, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| Delivery of relevant content and advertisements to you and measuring or understanding the effectiveness of the advertising we serve to you | (a) Email address (b) Device ID (c) IP Address (d) Location (at country, state, city, or postal code level) (e) Gender (f) Age (g) Technical Data (h) Cookies, pixels, or advertising tags |
(a) Necessary for our legitimate interests to deliver your Service-related content and communication as well as study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy (b) With your consent for targeted advertising and profiling to serve more accurate advertising content to you. |
| Response requests from law enforcement, including banks, card processing companies and investigation authorities | (a) Profile Data (b) Transaction Data (c) Communications Data (d) Location Data (at country, state, city, or postal code level) (e) Technical Data (f) Extended Data (g) Any other information we are compelled to provide by law or by terms of use of the respective organization. |
Necessary to comply with our legal obligations |
We may create aggregated data for internal use or for improving Services and creating new features. Aggregated data is anonymous and is not linked to any personal data. Aggregated information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. We may share such aggregated data with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
Automated Decision-Making (“ADM”) is when a decision is made solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless (a) you provide us with your consent, (b) ADM is authorized by law or (c) ADM is necessary for the performance of or entering into a contract.
We use ADM for:
some of our support functions, like requests to change your profile information, update your payment method, actualise service use details, etc., may be processed by our AI-based chatbot. The chatbot will always request for your consent for a particular action, and its activities will be logged in our files.
blocking or limiting features for the users when we detect prohibited content or violations of our Terms.
If you believe that ADM acted inappropriately or want to be serviced by a human, please CONTACT US.
Our Service id based on AI-based functions which supports scenarios you chose to interact or suggesting possible scenario development based on your decisions. This list may be enlarged in future. For that purpose we may transfer your respective data to the relevant AI model provided to us by the trusted partner. Your data are safe and will be processed only for the purposes of providing the respective services to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you have interacted with us, we will send you marketing communications from time to time. If you do not want to receive marketing communications, please refer to HOW TO OPT-OUT FROM E-MAIL MESSAGES down below. You may also select the “unsubscribe” link in the communication we send to you.
When you receive communications from Us, including marketing communications, we may share your personal data with third party companies who help us conduct marketing activities. For example, we may use a third party to help us send email messages to you and help us understand how you have interacted with that email.
You hereby agree that we may at our own discretion use any available channels of communication (including, but not limited to email) for marketing purposes if you have provided us with such. You may at any time withdraw your consent on such communication by contacting our support team via CONTACT US link down below.
We will generally only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
The personal 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 the Data controller, in some cases, the personal data may be accessible to certain types of persons in charge, involved with the operation of our Services (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data controller.
We may share your personal data you provide to us with specially selected service providers who assist us in delivering the products and services we offer for the sole purpose of providing the services or when we consider their services or products to be of interest to you. These service providers must adhere to strict confidentiality and data transfer obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them. We may cooperate with external service providers to:
oversee a customer personal data database;
help us in sending out your our communications;
help us with marketing activities;
assist us with storage and data analysis;
prevent from fraudulent activities;
help us in maintaining, developing and improving our systems/websites/applications/services;
collect payments.
We may disclose your personal data to other third parties such as our partners, consultors, group companies and affiliates, external audit and assessment providers provided they ensure the required level of confidentiality and privacy according to the applicable laws.
We may transfer or share a copy of your personal data in cases where the Data Controller or one of its properties, affiliates, or subsidiaries is part of a business transition, such as a merger, being acquired by another company, or selling part of its assets, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.
We may share your personal data to, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, our property or safety, our users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
We may share personal data internally within Data Controller’s subsidiary, affiliated and partner companies or with third parties for purposes described in this Privacy Policy. Personal data collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize standard contractual clauses approved by the European Commission, adopt other means under European Union law (such as, where applicable, corporate binding rules), and obtain your consent to legitimize data transfers from the EEA to the United States and other countries.
We will retain your personal data for as long as necessary to fulfill the purposes we collected and/or processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
The Personal data is processed at the Data controller’s operating offices and in any other place where the parties involved with the processing are located. We also retain backups of the Services, including your personal data, on a rolling basis according to our internal data retention, disaster recovery, and business continuity policies. Our backups are stored off-site in the European Union, United Stated and other countries where we operate, in secure facilities in order to help ensure the protection of your personal data, and the Services.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or other purposes in which case we may use this information indefinitely without further notice to you.
If you wish to delete personal data we have collected during your use of our Services, You should send a request to our support team via CONTACT US link down below. Processing of your request will take some time to take effect. Thank you for your patience.
Please note that changing or deleting your personal data will only change or delete the data in our database for the purposes of future activities and for managing future communications. These changes and deletions may not entirely change or delete emails or personal data our Services may have already forwarded to other users or credit card companies or any other third parties, as they might still retain part of the data for their legitimate or lawful purposes.
We may keep your personal data, subject to the requirements of the law and legitimate interests of the Data Controller, please refer to the HOW WE USE YOUR PERSONAL DATA section above for further details. In case of your request to delete all your personal data, you agree that your email will be stored in our database to avoid creation of duplicate accounts and for identification purposes. The email will not be used in marketing activities, nor forwarded to third parties.
Please note that, even after termination of Services and deletion of any personal data, as well as termination of any license granted hereunder, some content may continue to exist because of cached internet pages beyond our control.
You define which information you store with us and how we communicate with you. The tips below will help you to tune that properly.
You have the right, at any time, to change or delete your personal data in your profile. Please reach our support team via CONTACT US section down below and they will guide you through the process.
You can decide which correspondence to receive from us. To stop receiving correspondence you can:
Click the unsubscribe link found at the bottom of each email you receive or
by emailing your request to us at CONTACT US.
If you still have questions, please contact our support team via the CONTACT US section down below and they will guide you through the process.
We respect your privacy rights granted by the applicable laws. Regardless of your location, we will ensure that you have right to
Access data we process about you,
Correct and/or complete your data,
Delete your data subject to section HOW LONG WILL WE KEEP YOUR PERSONAL DATA,
Object to or restrict data processing according to the applicable laws and regulations, and
Be informed about any activity of the above.
You can exercise your rights by contacting our support team via the CONTACT US section of this Privacy Policy.
Please note that local regulations may provide other or additional rights to the above as following:
If you are located in the European Union, you have several rights under General Data Protection Regulation (“GDPR”):
You have the right to obtain confirmation if your personal information is being processed by us.
You have the right to receive your personal information which you provided us with in a structured,commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.
You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR.
If you are located in the United States, the local Data Privacy Acts give you the right to exercise the following rights in addition to the above:
Right to prohibit sale of your personal data. Please note that we do not sell your personal data.
Right to object profiling and targeted advertising. You may submit a verifiable request to be opted-out from each of the above actions. Please note that these measures may negatively affect your customer experience with our website, app and third party services.
Please note that the Privacy Acts vary from state to state. If you are based in the US, please consult your local certified legal advisor for more detailed regulation.
Your Data Controller’s contact information is: NOVI LIMITED, reg. number HE 407352, address Aglantzias, 62, EKATERINI NICOSIA BUSINESS, Flat/Office 213 CENTER, Aglantzia, 2108, Nicosia, Cyprus.
Please send all the requests, including exercise of rights for EU, US and other users regarding personal data, as well as communications, inquiries, clarifications and provision of information to our support team via chat in application (for registered users only) or via email at support@flirtuale.ai.
If you click on a link that takes you away from our Services to another website or application, you should remember that the Terms, Refund and Cancellation Policy and Privacy Policy of our Services no longer apply to the new website or application you visit. All your activity on any other website or application, including those with a link on the Services, is subject to the rules and regulations of that other website or application. Therefore, we recommend that you read all the policies of new websites and applications you visit to fully understand their rules and regulations for collecting, using, and sharing your personal data.
By posting any content, messages, photos and/or videos to any public area of our Services you automatically grant, represent and warrant that you have the right to grant us an irrevocable, perpetual, non-exclusive, fully paid, worldwide license to use, copy, perform, display, and distribute such personal data and content and to prepare derivative works of, or incorporate into other works, such personal data and content, and to grant and authorize sublicenses of the foregoing.
For the content that is covered by intellectual property rights, like photos and videos (the “IP content”), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with the Services (IP License). This IP License ends when you terminate our Services and we, according to this Privacy Policy, Refund and Cancellation Policy the Terms, delete your IP content unless your content has been shared with others, and they have not deleted it.
We reserve the right to replace, modify or amend this Privacy Policy at our own discretion. It is your responsibility to review this page and check for any Privacy Policy updates. Please note the latest modification date at the bottom of the Privacy Policy.