Last Update: November 2024
At Flipchat Inc., (“Flipchat”, “us”, “we”, “our”), we value and respect your privacy. Flipchat is our mobile application platform that facilitates interactions with third parties offering chat and communication services, enabling individuals and entities to make cryptocurrency payments for access to such chat or communication services (such platform, the “Flipchat App”). Users that pay in cryptocurrency to engage with third parties through the Flipchat App are referred to as “Users” and Users who offer chat or communication services in the Flipchat App are referred to as “Chat Hosts”.
We have prepared this privacy policy to explain the manner in which we collect, use, disclose and otherwise process personal information when you download and use the Flipchat App or use the Flipchat website located at flipchat.xyz, including all associated subdomains (the “Flipchat Website”) and in our other interactions with you (the “Privacy Policy”).
TABLE OF CONTENTS
COLLECTION AND USE OF PERSONAL INFORMATION
SHARING OF PERSONAL INFORMATION
INFORMATION ABOUT THE FLIPCHAT APP
INFORMATION ABOUT THE FLIPCHAT WEBSITE
THIRD PARTY LINKS
DATA TRANSFERS
SAFEGUARDS AND RETENTION
CHILDREN’S PRIVACY
DATA BREACH NOTIFICATION
YOUR CHOICES
PRIVACY GOVERNANCE POLICIES AND PRACTICES
UPDATES TO THE PRIVACY POLICY
CONTACT US
COLLECTION AND USE OF PERSONAL INFORMATION
Means of Collection
We collect personal information that you provide directly to us (through the Flipchat App, the Flipchat Website or through other communication channels) as well as information your devices provide to us automatically.
How we collect and use personal information through the Flipchat App or Flipchat Website and in our other interactions with you
We may collect personal information when you:
Create an account
Link an account to a third party platform
Join or participate in a chat room
Make a payment
Participate in our surveys
Sign up for marketing emails
Contact us with a comment, question or complaint
Creating an Account:
Before you can use the Flipchat App, you will be asked to provide a Display Name , which will be how you appear in Flipchat. You will also be prompted to save your Access Key, which is how you access your account if you’re logged out or switch devices. We will never ask you for your Access Key or other credentials in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.
We may request access to your contacts. We use this information to enable Users to invite and locate others with accounts in the Flipchat App.
We may allow Users to link their accounts with third-party platforms, such as Twitter/X, or other social media or external services (collectively, “Third-Party Platforms”). By choosing to link your account with a Third-Party Platform, you consent to the sharing of certain information between our app and the platform, as described below.
Joining a Chat Room:
Anyone in Flipchat is able to create a chat group (“Room”) with a unique identifier that can be shared with Users. Users will be required to enter the unique identifier and make a payment in the Flipchat App to join the Room. Please note that any content you post or otherwise make available in a Room will be viewable to anyone in the Room. You are solely responsible for the information you voluntarily share in group chats. Please exercise caution when sharing sensitive personal information, such as health, financial, or other private details. Remember, other participants can view and potentially store or share this information independently. By participating in group chats, you acknowledge and agree that any information you voluntarily share, including sensitive personal details, may be stored on our servers and visible to other participants.
We store group chat messages on our servers indefinitely to provide continuity and accessibility to Users. Users may request deletion of specific messages or their account to remove associated chat content. Sensitive information shared in chats remains stored until such a request is made.
Making a Payment:
When a User creates a Flipchat account they will be given a starting balance. This will be used to pay to get into Rooms. You can earn more by hosting a Room. We may also collect information about your cryptocurrency transactions (e.g., records of cryptocurrency sent to or received from other Flipchat Users) to help us verify and process your transactions and provide a record of activity in your account.
Surveys:
From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our Users and to enhance the Flipchat Website and Flipchat App.
Contact Us:
When you contact us with a comment, question or complaint through privacy@flipchat.xyz, you may be asked for information that identifies you, such as your name and telephone number, along with additional information such as email address we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.
SHARING OF PERSONAL INFORMATION
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
Affiliates:
We share your personal information within our group of companies, and these related group companies may only use your personal information in accordance with this Privacy Policy. These related group companies include Code Inc. (located in the United States) and 1000710770 Ontario Inc. (located in Canada) for the purposes of providing Flipchat to you, assisting us in carrying out the purposes set out in the “Collection and Use of Personal Information” Section, and carrying out our obligations and enforcing our rights under the Flipchat Terms of Service located at flipchat.xyz/tos or this Privacy Policy.
Account Integration with Third-Party Platforms:
We may share limited information back to the Third-Party Platform, such as, basic account details (e.g., Display Name, app activity related to the platform) and your permissions necessary to enable the integration or functionality you’ve requested.
Service Providers:
Your personal information may be transferred (or otherwise made available) to our affiliates and certain third parties that provide services on our behalf. We may use service providers to provide services such as hosting the Flipchat App and Flipchat Website, providing user authentication and verification services and offering opportunities to buy cryptocurrency. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our service providers may access, store and otherwise process personal information outside of the jurisdiction in which you are located, including in other provinces in Canada, the United States and other foreign jurisdictions.
Legal and Compliance:
We and our Canadian, U.S. and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business:
We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Flipchat or as part of a corporate reorganization or other change in corporate control.
INFORMATION ABOUT THE FLIPCHAT APP
In addition, when you install or use the Flipchat App, we may collect and use the following additional information.
Usage Information and Analytics:
As with many applications, certain limited data is required for the Flipchat App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the Flipchat App accesses our servers. We use this information to help us understand the activity on the Flipchat App, to monitor and improve the Flipchat App, and to tailor your Flipchat App experience. In addition, we may use third party service providers to collect analytical information about your use of the Flipchat App, such as the Flipchat App features used and time spent on the Flipchat App, to help us tailor your in-app experience, improve our products and the quality of the Flipchat App, and to manage and analyze data in order to better understand our Users.
Push Notifications:
If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with Flipchat App updates and other relevant information such as when a new message is sent to a chat Room you are a member of. If you wish to stop receiving push notifications from us, you can turn off push notifications for the Flipchat App either within the Flipchat App or in the settings of your mobile device.
INFORMATION ABOUT THE FLIPCHAT WEBSITE
Visiting the Flipchat Website:
In general, you can visit the Flipchat Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to the Flipchat Website and other related information such as page requests, browser type, operating system and average time spent on the Flipchat Website. We use this information to help us understand the Flipchat Website activity and to monitor and improve the Flipchat Website.
Cookies:
The Flipchat Website uses a technology called “cookies”. A cookie is a tiny element of data that the Flipchat Website sends to a user’s browser, which may then be stored on the user’s hard drive or other local storage so that we or third parties (such as our vendors or service providers) can recognize the user’s computer or device when they return. The data may contain a unique identifier or other information. Our vendors and service providers may use cookies or other technology to collect personally identifiable information about a user’s online activities over time and across different websites, including when using the Flipchat Website. We do not respond to browser-based “Do Not Track” signals. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Flipchat Website, you may not be able to take advantage of all of the Flipchat Website features.
THIRD PARTY LINKS
The Flipchat App and Flipchat Website may contain links to other websites that Flipchat does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.
DATA TRANSFERS
Your personal information may be processed outside of your jurisdiction, including in the U.S., Canada, and other countries. These regions may have different data protection laws than your place of residence. When transferring personal information outside of your jurisdiction, we implement appropriate safeguards to protect your data in compliance with applicable laws, including contractual obligations for service providers.
SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements. Specific retention periods are determined based on:
Legal and regulatory obligations (e.g., tax, accounting, or reporting requirements).
Business needs to provide and improve our services.
When personal information is no longer required, we securely delete, anonymize, or destroy it in accordance with our data retention and destruction policies.
CHILDREN’S PRIVACY
The Flipchat App is not intended for children under 13. We do not knowingly collect data from children under 13 without parental consent. If you believe we have collected such information, please contact us at privacy@flipchat.xyz
DATA BREACH NOTIFICATION
In the event of a data breach, we will notify affected users and regulatory authorities as required by applicable laws in the U.S. and Canada.
YOUR CHOICES
Marketing Communications
If you have signed up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt out of receiving our marketing communications by contacting us using the contact information under “Contact Us” below.
Exercising Your Privacy Rights
Subject to applicable law, you have the right to access, update, rectify and correct inaccuracies in, and withdraw consent to the processing of, your personal information in our custody or control. You may make such a request or withdraw consent by emailing or writing to us using the contact information set out below. We may request certain personal information for the purpose of verifying your identity when you seek access to your personal information.
PRIVACY GOVERNANCE POLICIES AND PRACTICES
We have implemented governance policies and practices to ensure compliance with privacy laws and safeguard your personal information. These include:
Privacy Officer: A designated individual responsible for overseeing compliance with privacy legislation.
Staff Training: Regular training programs for employees to handle personal information securely and lawfully.
Privacy Impact Assessments: Conducted for new or high-risk data processing activities to identify and mitigate risks.
Data Retention Policies: Established timelines for data retention and secure destruction.
Complaint Handling: Procedures to address inquiries and complaints related to privacy in a timely manner.
UPDATES TO THE PRIVACY POLICY
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.
CONTACT US
If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please contact us at:
Eileen Lyon, CCO
Flipchat Inc., 15233 Ventura Blvd., Suite 1220, Sherman Oaks, CA 91403
