Privacy Policy

<h1>PRIVACY POLICY</h1>
Last updated: January 01, 2026


This Privacy Notice for Fluencify AB (doing business as Fluencify) ("we,"
"us," or "our"), describes how and why we might access, collect, store,
use, and/or share ("process") your personal information when you use our
services ("Services"), including when you:


<ul>
<li>
Visit our website at
<a href="https://www.fluencify.io">https://www.fluencify.io</a> or any
website of ours that links to this Privacy Notice
</li>
<li>
Download and use our mobile application (Fluencify - Get Paid to
Create), or any other application of ours that links to this Privacy
Notice
</li>
<li>
Engage with us in other related ways, including any marketing or events
</li>
</ul>


Questions or concerns? Reading this Privacy Notice will
help you understand your privacy rights and choices. We are responsible
for making decisions about how your personal information is processed. If
you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns, please contact us
at <a href="mailto:[email protected]">[email protected]</a>.


<h2>SUMMARY OF KEY POINTS</h2>


This summary provides key points from our Privacy Notice, but you can
find out more details about any of these topics by clicking the link
following each key point or by using our
<a href="#toc">table of contents</a> below to find the section you are
looking for.



What personal information do we process? When you visit,
use, or navigate our Services, we may process personal information
depending on how you interact with us and the Services, the choices you
make, and the products and features you use. Learn more about
<a href="#personalinfo">personal information you disclose to us</a>.



Do we process any sensitive personal information? Some of
the information may be considered "special" or "sensitive" in certain
jurisdictions, for example your racial or ethnic origins, sexual
orientation, and religious beliefs. We do not process sensitive personal
information.



Do we collect any information from third parties? We do
not collect any information from third parties.



How do we process your information? We process your
information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We
may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so.
Learn more about <a href="#infouse">how we process your information</a>.



In what situations and with which parties do we share personal
information?
We may share information in specific situations and with specific third
parties. Learn more about
<a href="#whoshare"
>when and with whom we share your personal information</a
>.



How do we keep your information safe? We have adequate
organizational and technical processes and procedures in place to protect
your personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information. Learn
more about <a href="#infosafe">how we keep your information safe</a>.



What are your rights? Depending on where you are located
geographically, the applicable privacy law may mean you have certain
rights regarding your personal information. Learn more about
<a href="#privacyrights">your privacy rights</a>.



How do you exercise your rights? The easiest way to
exercise your rights is by visiting
<a href="mailto:[email protected]">[email protected]</a>, or by
contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.



Want to learn more about what we do with any information we collect?
<a href="#toc">Review the Privacy Notice in full</a>.


<h2 id="toc">TABLE OF CONTENTS</h2>

<ol>
<li><a href="#infocollect">WHAT INFORMATION DO WE COLLECT?</a></li>
<li><a href="#infouse">HOW DO WE PROCESS YOUR INFORMATION?</a></li>
<li>
<a href="#legalbases"
>WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?</a
>
</li>
<li>
<a href="#whoshare"
>WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?</a
>
</li>
<li>
<a href="#cookies"
>DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?</a
>
</li>
<li>
<a href="#ai">DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?</a>
</li>
<li><a href="#sociallogins">HOW DO WE HANDLE YOUR SOCIAL LOGINS?</a></li>
<li>
<a href="#intltransfers"
>IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?</a
>
</li>
<li><a href="#inforetain">HOW LONG DO WE KEEP YOUR INFORMATION?</a></li>
<li><a href="#infosafe">HOW DO WE KEEP YOUR INFORMATION SAFE?</a></li>
<li><a href="#infominors">DO WE COLLECT INFORMATION FROM MINORS?</a></li>
<li><a href="#privacyrights">WHAT ARE YOUR PRIVACY RIGHTS?</a></li>
<li><a href="#DNT">CONTROLS FOR DO-NOT-TRACK FEATURES</a></li>
<li>
<a href="#uslaws"
>DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?</a
>
</li>
<li>
<a href="#otherlaws">DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?</a>
</li>
<li><a href="#policyupdates">DO WE MAKE UPDATES TO THIS NOTICE?</a></li>
<li><a href="#contact">HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</a></li>
<li>
<a href="#request"
>HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?</a
>
</li>
</ol>

<h2 id="infocollect">1. WHAT INFORMATION DO WE COLLECT?</h2>

<h3 id="personalinfo">Personal information you disclose to us</h3>


In Short:
We collect personal information that you provide to us.



We collect personal information that you voluntarily provide to us when
you register on the Services, express an interest in obtaining information
about us or our products and Services, when you participate in activities
on the Services, or otherwise when you contact us.



Personal Information Provided by You. The personal
information that we collect depends on the context of your interactions
with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the
following:


<ul>
<li>names</li>
<li>phone numbers</li>
<li>email addresses</li>
</ul>


Sensitive Information. We do not process sensitive
information.



Payment Data. We may collect data necessary to process
your payment if you choose to make purchases, such as your payment
instrument number, and the security code associated with your payment
instrument. All payment data is handled and stored by Stripe. You may find
their privacy notice link(s) here:
<a href="https://stripe.com/privacy">https://stripe.com/privacy</a>.



Social Media Login Data. We may provide you with the
option to register with us using your existing social media account
details, like your Facebook, X, or other social media account. If you
choose to register in this way, we will collect certain profile
information about you from the social media provider, as described in the
section called "<a href="#sociallogins"
>HOW DO WE HANDLE YOUR SOCIAL LOGINS?</a
>" below.



Application Data. If you use our application(s), we also
may collect the following information if you choose to provide us with
access or permission:


<ul>
<li>
Mobile Device Access. We may request access or permission to
certain features from your mobile device, including your mobile device's
storage, camera, and other features. If you wish to change our access or
permissions, you may do so in your device's settings.
</li>
<li>
Mobile Device Data. We automatically collect device information
(such as your mobile device ID, model, and manufacturer), operating
system, version information and system configuration information, device
and application identification numbers, browser type and version,
hardware model Internet service provider and/or mobile carrier, and
Internet Protocol (IP) address (or proxy server). If you are using our
application(s), we may also collect information about the phone network
associated with your mobile device, your mobile device's operating
system or platform, the type of mobile device you use, your mobile
device's unique device ID, and information about the features of our
application(s) you accessed.
</li>
<li>
Push Notifications. We may request to send you push
notifications regarding your account or certain features of the
application(s). If you wish to opt out from receiving these types of
communications, you may turn them off in your device's settings.
</li>
</ul>


This information is primarily needed to maintain the security and
operation of our application(s), for troubleshooting, and for our internal
analytics and reporting purposes.



All personal information that you provide to us must be true, complete,
and accurate, and you must notify us of any changes to such personal
information.


<h3>Information automatically collected</h3>


In Short:
Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you
visit our Services.



We automatically collect certain information when you visit, use, or
navigate the Services. This information does not reveal your specific
identity (like your name or contact information) but may include device
and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our
Services, and other technical information. This information is primarily
needed to maintain the security and operation of our Services, and for our
internal analytics and reporting purposes.



Like many businesses, we also collect information through cookies and
similar technologies.


The information we collect includes:

<ul>
<li>
Log and Usage Data. Log and usage data is service-related,
diagnostic, usage, and performance information our servers automatically
collect when you access or use our Services and which we record in log
files. Depending on how you interact with us, this log data may include
your IP address, device information, browser type, and settings and
information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches, and
other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called
"crash dumps"), and hardware settings).
</li>
<li>
Device Data. We collect device data such as information about
your computer, phone, tablet, or other device you use to access the
Services. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware
model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
</li>
<li>
Location Data. We collect location data such as information
about your device's location, which can be either precise or imprecise.
How much information we collect depends on the type and settings of the
device you use to access the Services. For example, we may use GPS and
other technologies to collect geolocation data that tells us your
current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the
information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain
aspects of the Services.
</li>
</ul>

<h3>Google API</h3>


Our use of information received from Google APIs will adhere to
<a
href="https://developers.google.com/terms/api-services-user-data-policy"
>Google API Services User Data Policy</a
>, including the
<a
href="https://developers.google.com/terms/api-services-user-data-policy#limited-use"
>Limited Use requirements</a
>.


<h2 id="infouse">2. HOW DO WE PROCESS YOUR INFORMATION?</h2>


In Short:
We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and
to comply with law. We process the personal information for the
following purposes listed below. We may also process your information
for other purposes only with your prior explicit consent.



We process your personal information for a variety of reasons,
depending on how you interact with our Services, including:


<ul>
<li>
To facilitate account creation and authentication and otherwise
manage user accounts.
We may process your information so you can create and log in to your
account, as well as keep your account in working order.
</li>
<li>
To enable user-to-user communications. We may process
your information if you choose to use any of our offerings that allow
for communication with another user.
</li>
<li>
To request feedback. We may process your information
when necessary to request feedback and to contact you about your use of
our Services.
</li>
<li>
To send you marketing and promotional communications.
We may process the personal information you send to us for our marketing
purposes, if this is in accordance with your marketing preferences. You
can opt out of our marketing emails at any time. For more information,
see "<a href="#privacyrights">WHAT ARE YOUR PRIVACY RIGHTS?</a>" below.
</li>
<li>
To protect our Services. We may process your
information as part of our efforts to keep our Services safe and secure,
including fraud monitoring and prevention.
</li>
<li>
To identify usage trends. We may process information
about how you use our Services to better understand how they are being
used so we can improve them.
</li>
<li>
To save or protect an individual's vital interest. We
may process your information when necessary to save or protect an
individual's vital interest, such as to prevent harm.
</li>
</ul>

<h2 id="legalbases">
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
</h2>


In Short:
We only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e., legal basis) to do so
under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate
business interests.


<h3>
If you are located in the EU or UK, this section applies to you.
</h3>


The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process
your personal information:


<ul>
<li>
Consent. We may process your information if you have
given us permission (i.e., consent) to use your personal information for
a specific purpose. You can withdraw your consent at any time. Learn
more about <a href="#withdrawconsent">withdrawing your consent</a>.
</li>
<li>
Performance of a Contract. We may process your personal
information when we believe it is necessary to fulfill our contractual
obligations to you, including providing our Services or at your request
prior to entering into a contract with you.
</li>
<li>
Legitimate Interests. We may process your information
when we believe it is reasonably necessary to achieve our legitimate
business interests and those interests do not outweigh your interests
and fundamental rights and freedoms. For example, we may process your
personal information for some of the purposes described in order to:
<ul>
<li>
Send users information about special offers and discounts on our
products and services
</li>
<li>
Analyze how our Services are used so we can improve them to engage
and retain users
</li>
<li>Diagnose problems and/or prevent fraudulent activities</li>
<li>
Understand how our users use our products and services so we can
improve user experience
</li>
</ul>
</li>
<li>
Legal Obligations. We may process your information
where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
</li>
<li>
Vital Interests. We may process your information where
we believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential
threats to the safety of any person.
</li>
</ul>

<h3>If you are located in Canada, this section applies to you.</h3>


We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e.,
implied consent). You can
<a href="#withdrawconsent">withdraw your consent</a> at any time.



In some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for
example:


<ul>
<li>
If collection is clearly in the interests of an individual and consent
cannot be obtained in a timely way
</li>
<li>For investigations and fraud detection and prevention</li>
<li>For business transactions provided certain conditions are met</li>
<li>
If it is contained in a witness statement and the collection is
necessary to assess, process, or settle an insurance claim
</li>
<li>
For identifying injured, ill, or deceased persons and communicating with
next of kin
</li>
<li>
If we have reasonable grounds to believe an individual has been, is, or
may be victim of financial abuse
</li>
<li>
If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach
of an agreement or a contravention of the laws of Canada or a province
</li>
<li>
If disclosure is required to comply with a subpoena, warrant, court
order, or rules of the court relating to the production of records
</li>
<li>
If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the
purposes for which the information was produced
</li>
<li>
If the collection is solely for journalistic, artistic, or literary
purposes
</li>
<li>
If the information is publicly available and is specified by the
regulations
</li>
<li>
We may disclose de-identified information for approved research or
statistics projects, subject to ethics oversight and confidentiality
commitments
</li>
</ul>

<h2 id="whoshare">
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
</h2>


In Short:
We may share information in specific situations described in this
section and/or with the following third parties.



Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers,
contractors, or agents ("third parties") who perform services for us or on
our behalf and require access to such information to do that work. We have
contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do
anything with your personal information unless we have instructed them to
do it. They will also not share your personal information with any
organization apart from us. They also commit to protect the data they hold
on our behalf and to retain it for the period we instruct.



The third parties we may share personal information with are as follows:


<ul>
<li>AI Service Providers: Anthropic</li>
<li>Cloud Computing Services: Convex</li>
<li>Communicate and Chat with Users: Resend</li>
<li>Invoice and Billing: Stripe</li>
<li>
User Account Registration and Authentication: Clerk
</li>
<li>Web and Mobile Analytics: PostHog</li>
<li>Website Hosting: Vercel</li>
<li>Website Performance Monitoring: PostHog</li>
</ul>


We also may need to share your personal information in the following
situations:


<ul>
<li>
Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
</li>
<li>
Other Users. When you share personal information (for
example, by posting comments, contributions, or other content to the
Services) or otherwise interact with public areas of the Services, such
personal information may be viewed by all users and may be publicly made
available outside the Services in perpetuity. If you interact with other
users of our Services and register for our Services through a social
network (such as Facebook), your contacts on the social network will see
your name, profile photo, and descriptions of your activity. Similarly,
other users will be able to view descriptions of your activity,
communicate with you within our Services, and view your profile.
</li>
<li>
Offer Wall. Our application(s) may display a
third-party hosted "offer wall." Such an offer wall allows third-party
advertisers to offer virtual currency, gifts, or other items to users in
return for the acceptance and completion of an advertisement offer. Such
an offer wall may appear in our application(s) and be displayed to you
based on certain data, such as your geographic area or demographic
information. When you click on an offer wall, you will be brought to an
external website belonging to other persons and will leave our
application(s). A unique identifier, such as your user ID, will be
shared with the offer wall provider in order to prevent fraud and
properly credit your account with the relevant reward.
</li>
</ul>

<h2 id="cookies">5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?</h2>


In Short:
We may use cookies and other tracking technologies to collect and store
your information.



We may use cookies and similar tracking technologies (like web beacons and
pixels) to gather information when you interact with our Services. Some
online tracking technologies help us maintain the security of our Services
and your account, prevent crashes, fix bugs, save your preferences, and
assist with basic site functions.



We also permit third parties and service providers to use online tracking
technologies on our Services for analytics and advertising, including to
help manage and display advertisements, to tailor advertisements to your
interests, or to send abandoned shopping cart reminders (depending on your
communication preferences). The third parties and service providers use
their technology to provide advertising about products and services
tailored to your interests which may appear either on our Services or on
other websites.



To the extent these online tracking technologies are deemed to be a
"sale"/"sharing" (which includes targeted advertising, as defined under
the applicable laws) under applicable US state laws, you can opt out of
these online tracking technologies by submitting a request as described
below under section "<a href="#uslaws"
>DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?</a
>"



Specific information about how we use such technologies and how you can
refuse certain cookies is set out in our Cookie Notice.


<h2 id="ai">6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?</h2>


In Short:
We offer products, features, or tools powered by artificial
intelligence, machine learning, or similar technologies.



As part of our Services, we offer products, features, or tools powered by
artificial intelligence, machine learning, or similar technologies
(collectively, "AI Products"). These tools are designed to enhance your
experience and provide you with innovative solutions. The terms in this
Privacy Notice govern your use of the AI Products within our Services.


<h3>Use of AI Technologies</h3>


We provide the AI Products through third-party service providers ("AI
Service Providers"), including Anthropic. As outlined in this Privacy
Notice, your input, output, and personal information will be shared with
and processed by these AI Service Providers to enable your use of our AI
Products for purposes outlined in "<a href="#legalbases"
>WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?</a
>" You must not use the AI Products in any way that violates the terms or
policies of any AI Service Provider.


<h3>Our AI Products</h3>

Our AI Products are designed for the following functions:

<ul>
<li>Customer Support / Automated Assistance</li>
</ul>

<h3>How We Process Your Data Using AI</h3>


All personal information processed using our AI Products is handled in
line with our Privacy Notice and our agreement with third parties. This
ensures high security and safeguards your personal information throughout
the process, giving you peace of mind about your data's safety.


<h3>How to Opt Out</h3>


We believe in giving you the power to decide how your data is used. To opt
out, you can:


<ul>
<li>Contact us using the contact information provided</li>
</ul>

<h2 id="sociallogins">7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?</h2>


In Short:
If you choose to register or log in to our Services using a social
media account, we may have access to certain information about you.



Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or X logins).
Where you choose to do this, we will receive certain profile information
about you from your social media provider. The profile information we
receive may vary depending on the social media provider concerned, but
will often include your name, email address, friends list, and profile
picture, as well as other information you choose to make public on such a
social media platform.



We will use the information we receive only for the purposes that are
described in this Privacy Notice or that are otherwise made clear to you
on the relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on
their sites and apps.


<h2 id="intltransfers">
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
</h2>


In Short:
We may transfer, store, and process your information in countries other
than your own.



Our servers are located in the United States and Germany. Regardless of
your location, please be aware that your information may be transferred
to, stored by, and processed by us in our facilities and in the facilities
of the third parties with whom we may share your personal information (see
"<a href="#whoshare"
>WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?</a
>" above), including facilities in the United States, Germany, and other
countries.



If you are a resident in the European Economic Area (EEA), United Kingdom
(UK), or Switzerland, then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to protect your
personal information in accordance with this Privacy Notice and applicable
law.


European Commission's Standard Contractual Clauses:


We have implemented measures to protect your personal information,
including by using the European Commission's Standard Contractual Clauses
for transfers of personal information between our group companies and
between us and our third-party providers. These clauses require all
recipients to protect all personal information that they process
originating from the EEA or UK in accordance with European data protection
laws and regulations. Our Standard Contractual Clauses can be provided
upon request. We have implemented similar appropriate safeguards with our
third-party service providers and partners and further details can be
provided upon request.


<h2 id="inforetain">9. HOW LONG DO WE KEEP YOUR INFORMATION?</h2>


In Short:
We keep your information for as long as necessary to fulfill the
purposes outlined in this Privacy Notice unless otherwise required by
law.



We will only keep your personal information for as long as it is necessary
for the purposes set out in this Privacy Notice, unless a longer retention
period is required or permitted by law (such as tax, accounting, or other
legal requirements). No purpose in this notice will require us keeping
your personal information for longer than the period of time in which
users have an account with us.



When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if
this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.


<h2 id="infosafe">10. HOW DO WE KEEP YOUR INFORMATION SAFE?</h2>


In Short:
We aim to protect your personal information through a system of
organizational and technical security measures.



We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your
own risk. You should only access the Services within a secure environment.


<h2 id="infominors">11. DO WE COLLECT INFORMATION FROM MINORS?</h2>


In Short:
We do not knowingly collect data from or market to children under 18
years of age or the equivalent age as specified by law in your
jurisdiction.



We do not knowingly collect, solicit data from, or market to children
under 18 years of age or the equivalent age as specified by law in your
jurisdiction, nor do we knowingly sell such personal information. By using
the Services, you represent that you are at least 18 or the equivalent age
as specified by law in your jurisdiction or that you are the parent or
guardian of such a minor and consent to such minor dependent's use of the
Services. If we learn that personal information from users less than 18
years of age or the equivalent age as specified by law in your
jurisdiction has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18
or the equivalent age as specified by law in your jurisdiction, please
contact us at
<a href="mailto:[email protected]">[email protected]</a>.


<h2 id="privacyrights">12. WHAT ARE YOUR PRIVACY RIGHTS?</h2>


In Short:
Depending on your state of residence in the US or in some regions, such
as the European Economic Area (EEA), United Kingdom (UK), Switzerland,
and Canada, you have rights that allow you greater access to and control
over your personal information. You may review, change, or terminate
your account at any time, depending on your country, province, or state
of residence.



In some regions (like the EEA, UK, Switzerland, and Canada), you have
certain rights under applicable data protection laws. These may include
the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; (iv) if applicable, to data
portability; and (v) not to be subject to automated decision-making. If a
decision that produces legal or similarly significant effects is made
solely by automated means, we will inform you, explain the main factors,
and offer a simple way to request human review. In certain circumstances,
you may also have the right to object to the processing of your personal
information. You can make such a request by contacting us by using the
contact details provided in the section "<a href="#contact"
>HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</a
>" below.



We will consider and act upon any request in accordance with applicable
data protection laws.



If you are located in the EEA or UK and you believe we are unlawfully
processing your personal information, you also have the right to complain
to your
<a
href="https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm"
>Member State data protection authority</a
>
or
<a
href="https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/"
>UK data protection authority</a
>.



If you are located in Switzerland, you may contact the
<a href="https://www.edoeb.admin.ch/edoeb/en/home.html"
>Federal Data Protection and Information Commissioner</a
>.



Withdrawing your consent: If we are relying on
your consent to process your personal information, which may be express
and/or implied consent depending on the applicable law, you have the right
to withdraw your consent at any time. You can withdraw your consent at any
time by contacting us by using the contact details provided in the section
"<a href="#contact">HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</a>" below.



However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law allows, will it
affect the processing of your personal information conducted in reliance
on lawful processing grounds other than consent.



Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at
any time by clicking on the unsubscribe link in the emails that we send,
or by contacting us using the details provided in the section "<a
href="#contact"
>HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</a
>" below. You will then be removed from the marketing lists. However, we
may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your
account, to respond to service requests, or for other non-marketing
purposes.


<h3>Account Information</h3>


If you would at any time like to review or change the information in your
account or terminate your account, you can:


<ul>
<li>
Log in to your account settings and update your user account. Contact us
using the contact information provided to delete your user account.
</li>
</ul>


Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.


<h3>Account Deletion and Data Retention</h3>


30-Day Deactivation Period: When you request account
deletion through the App's account settings, your account enters a 30-day
deactivation period. During this period, your account is inactive but not
permanently deleted. If you log back in during this period, the deletion
request is automatically cancelled and your account will be reactivated.
After 30 days of no activity, your account is permanently deleted.



Prerequisites for Deletion: Before your deletion request
can be processed, you must complete or withdraw from all active campaigns.
Any pending video submissions will have the 30-day period to be reviewed
by Brands.



What Gets Deleted: Upon permanent deletion, the following
data will be removed from our systems:


<ul>
<li>Personal information (name, email address, phone number)</li>
<li>
Profile data and uploaded identity documents, including the actual photo
files stored in our systems
</li>
<li>
Pending and rejected video submissions, including the actual video files
stored in our systems
</li>
<li>Chat messages and communications</li>
<li>Payment method settings</li>
<li>Profile images and any other uploaded media files</li>
</ul>


What Gets Retained (and why): Certain information may be
retained after account deletion:


<ul>
<li>
Approved campaign videos: Retained under the perpetual
license granted in our Terms of Service. These videos have been paid for
by Brands and the license survives account termination.
</li>
<li>
Payout records: Retained for tax, accounting, and legal
compliance purposes (typically 7 years as required by law).
</li>
<li>
Campaign participation history: May be retained in
anonymized form for Brand reporting purposes.
</li>
</ul>


Pending Payouts: Any pending payouts will continue to be
processed during the 30-day deactivation period. Unpaid earnings remaining
after the 30-day period will be forfeited.



Cookies and similar technologies: Most Web
browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies, this could
affect certain features or services of our Services.



If you have questions or comments about your privacy rights, you may email
us at <a href="mailto:[email protected]">[email protected]</a>.


<h2 id="DNT">13. CONTROLS FOR DO-NOT-TRACK FEATURES</h2>


Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting you can
activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice
not to be tracked online. If a standard for online tracking is adopted
that we must follow in the future, we will inform you about that practice
in a revised version of this Privacy Notice.



California law requires us to let you know how we respond to web browser
DNT signals. Because there currently is not an industry or legal standard
for recognizing or honoring DNT signals, we do not respond to them at this
time.


<h2 id="uslaws">
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
</h2>


In Short:
If you are a resident of California, Colorado, Connecticut, Delaware,
Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana,
Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee,
Texas, Utah, or Virginia, you may have the right to request access to
and receive details about the personal information we maintain about you
and how we have processed it, correct inaccuracies, get a copy of, or
delete your personal information. You may also have the right to
withdraw your consent to our processing of your personal information.
These rights may be limited in some circumstances by applicable law.
More information is provided below.


<h3>Categories of Personal Information We Collect</h3>


The table below shows the categories of personal information we have
collected in the past twelve (12) months. The table includes illustrative
examples of each category and does not reflect the personal information we
collect from you. For a comprehensive inventory of all personal
information we process, please refer to the section "<a
href="#infocollect"
>WHAT INFORMATION DO WE COLLECT?</a
>"


<table border="1" cellpadding="10">
<thead>
<tr>
<th>Category</th>
<th>Examples</th>
<th>Collected</th>
</tr>
</thead>
<tbody>
<tr>
<td>A. Identifiers</td>
<td>
Contact details, such as real name, alias, postal address, telephone
or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address, and account
name
</td>
<td>YES</td>
</tr>
<tr>
<td>
B. Personal information as defined in the California Customer
Records statute
</td>
<td>
Name, contact information, education, employment, employment
history, and financial information
</td>
<td>YES</td>
</tr>
<tr>
<td>
C. Protected classification characteristics under state or federal
law
</td>
<td>
Gender, age, date of birth, race and ethnicity, national origin,
marital status, and other demographic data
</td>
<td>YES</td>
</tr>
<tr>
<td>D. Commercial information</td>
<td>
Transaction information, purchase history, financial details, and
payment information
</td>
<td>NO</td>
</tr>
<tr>
<td>E. Biometric information</td>
<td>Fingerprints and voiceprints</td>
<td>NO</td>
</tr>
<tr>
<td>F. Internet or other similar network activity</td>
<td>
Browsing history, search history, online behavior, interest data,
and interactions with our and other websites, applications, systems,
and advertisements
</td>
<td>NO</td>
</tr>
<tr>
<td>G. Geolocation data</td>
<td>Device location</td>
<td>YES</td>
</tr>
<tr>
<td>H. Audio, electronic, sensory, or similar information</td>
<td>
Images and audio, video or call recordings created in connection
with our business activities
</td>
<td>NO</td>
</tr>
<tr>
<td>I. Professional or employment-related information</td>
<td>
Business contact details in order to provide you our Services at a
business level or job title, work history, and professional
qualifications if you apply for a job with us
</td>
<td>NO</td>
</tr>
<tr>
<td>J. Education Information</td>
<td>Student records and directory information</td>
<td>NO</td>
</tr>
<tr>
<td>K. Inferences drawn from collected personal information</td>
<td>
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an
individual's preferences and characteristics
</td>
<td>YES</td>
</tr>
<tr>
<td>L. Sensitive personal Information</td>
<td></td>
<td>NO</td>
</tr>
</tbody>
</table>


We may also collect other personal information outside of these categories
through instances where you interact with us in person, online, or by
phone or mail in the context of:


<ul>
<li>Receiving help through our customer support channels;</li>
<li>Participation in customer surveys or contests; and</li>
<li>
Facilitation in the delivery of our Services and to respond to your
inquiries.
</li>
</ul>


We will use and retain the collected personal information as needed to
provide the Services or for:


<ul>
<li>Category A - As long as the user has an account with us</li>
<li>Category B - As long as the user has an account with us</li>
<li>Category C - As long as the user has an account with us</li>
<li>Category G - As long as the user has an account with us</li>
<li>Category K - As long as the user has an account with us</li>
</ul>

<h3>Sources of Personal Information</h3>


Learn more about the sources of personal information we collect in "<a
href="#infocollect"
>WHAT INFORMATION DO WE COLLECT?</a
>"


<h3>How We Use and Share Personal Information</h3>


Learn more about how we use your personal information in the section, "<a
href="#infouse"
>HOW DO WE PROCESS YOUR INFORMATION?</a
>"


Will your information be shared with anyone else?


We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider. Learn
more about how we disclose personal information to in the section, "<a
href="#whoshare"
>WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?</a
>"



We may use your personal information for our own business purposes, such
as for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal
information.



We have not sold or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We
have disclosed the following categories of personal information to third
parties for a business or commercial purpose in the preceding twelve (12)
months:


<ul>
<li>Category A. Identifiers</li>
<li>
Category B. Personal information as defined in the California Customer
Records law
</li>
<li>
Category C. Characteristics of protected classifications under state or
federal law
</li>
<li>Category G. Geolocation data</li>
</ul>


The categories of third parties to whom we disclosed personal information
for a business or commercial purpose can be found under "<a
href="#whoshare"
>WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?</a
>"


<h3>Your Rights</h3>


You have rights under certain US state data protection laws. However,
these rights are not absolute, and in certain cases, we may decline your
request as permitted by law. These rights include:


<ul>
<li>
Right to know whether or not we are processing your
personal data
</li>
<li>Right to access your personal data</li>
<li>
Right to correct inaccuracies in your personal data
</li>
<li>
Right to request the deletion of your personal data
</li>
<li>
Right to obtain a copy of the personal data you
previously shared with us
</li>
<li>
Right to non-discrimination for exercising your rights
</li>
<li>
Right to opt out of the processing of your personal
data if it is used for targeted advertising (or sharing as defined under
California's privacy law), the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ("profiling")
</li>
</ul>


Depending upon the state where you live, you may also have the following
rights:


<ul>
<li>
Right to access the categories of personal data being processed (as
permitted by applicable law, including the privacy law in Minnesota)
</li>
<li>
Right to obtain a list of the categories of third parties to which we
have disclosed personal data (as permitted by applicable law, including
the privacy law in California, Delaware, and Maryland)
</li>
<li>
Right to obtain a list of specific third parties to which we have
disclosed personal data (as permitted by applicable law, including the
privacy law in Minnesota and Oregon)
</li>
<li>
Right to obtain a list of third parties to which we have sold personal
data (as permitted by applicable law, including the privacy law in
Connecticut)
</li>
<li>
Right to review, understand, question, and depending on where you live,
correct how personal data has been profiled (as permitted by applicable
law, including the privacy law in Connecticut and Minnesota)
</li>
<li>
Right to limit use and disclosure of sensitive personal data (as
permitted by applicable law, including the privacy law in California)
</li>
<li>
Right to opt out of the collection of sensitive data and personal data
collected through the operation of a voice or facial recognition feature
(as permitted by applicable law, including the privacy law in Florida)
</li>
</ul>

<h3>How to Exercise Your Rights</h3>


To exercise these rights, you can contact us by visiting
<a href="mailto:[email protected]">[email protected]</a>, by
emailing us at
<a href="mailto:[email protected]">[email protected]</a>, or by
referring to the contact details at the bottom of this document.



Under certain US state data protection laws, you can designate an
authorized agent to make a request on your behalf. We may deny a request
from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with applicable
laws.


<h3>Request Verification</h3>


Upon receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the information in
our system. We will only use personal information provided in your request
to verify your identity or authority to make the request. However, if we
cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes.



If you submit the request through an authorized agent, we may need to
collect additional information to verify your identity before processing
your request and the agent will need to provide a written and signed
permission from you to submit such request on your behalf.


<h3>Appeals</h3>


Under certain US state data protection laws, if we decline to take action
regarding your request, you may appeal our decision by emailing us at
<a href="mailto:[email protected]">[email protected]</a>. We will
inform you in writing of any action taken or not taken in response to the
appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may submit a complaint to your state
attorney general.


<h3>California "Shine The Light" Law</h3>


California Civil Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a
request, please submit your request in writing to us by using the contact
details provided in the section "<a href="#contact"
>HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</a
>"


<h2 id="otherlaws">15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?</h2>


In Short:
You may have additional rights based on the country you reside in.


<h3>Australia and New Zealand</h3>


We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy
Act 2020 (Privacy Act).



This Privacy Notice satisfies the notice requirements defined in both
Privacy Acts, in particular: what personal information we collect from
you, from which sources, for which purposes, and other recipients of your
personal information.



If you do not wish to provide the personal information necessary to
fulfill their applicable purpose, it may affect our ability to provide our
services, in particular:


<ul>
<li>offer you the products or services that you want</li>
<li>respond to or help with your requests</li>
<li>manage your account with us</li>
<li>confirm your identity and protect your account</li>
</ul>


At any time, you have the right to request access to or correction of your
personal information. You can make such a request by contacting us by
using the contact details provided in the section "<a href="#request"
>HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?</a
>"



If you believe we are unlawfully processing your personal information, you
have the right to submit a complaint about a breach of the Australian
Privacy Principles to the
<a
href="https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us"
>Office of the Australian Information Commissioner</a
>
and a breach of New Zealand's Privacy Principles to the
<a href="https://www.privacy.org.nz/your-rights/making-a-complaint/"
>Office of New Zealand Privacy Commissioner</a
>.


<h3>Republic of South Africa</h3>


At any time, you have the right to request access to or correction of your
personal information. You can make such a request by contacting us by
using the contact details provided in the section "<a href="#request"
>HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?</a
>"



If you are unsatisfied with the manner in which we address any complaint
with regard to our processing of personal information, you can contact the
office of the regulator, the details of which are:



<a href="https://inforegulator.org.za/"
>The Information Regulator (South Africa)</a
> 
General enquiries:
<a href="mailto:[email protected]"
>[email protected]</a
> 
Complaints (complete POPIA/PAIA form 5):
<a href="mailto:[email protected]"
>[email protected]</a
>
&
<a href="mailto:[email protected]"
>[email protected]</a
>


<h2 id="policyupdates">16. DO WE MAKE UPDATES TO THIS NOTICE?</h2>


In Short:
Yes, we will update this notice as necessary to stay compliant with
relevant laws.



We may update this Privacy Notice from time to time. The updated version
will be indicated by an updated "Revised" date at the top of this Privacy
Notice. If we make material changes to this Privacy Notice, we may notify
you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this Privacy Notice
frequently to be informed of how we are protecting your information.


<h2 id="contact">17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?</h2>


If you have questions or comments about this notice, you may email us at
<a href="mailto:[email protected]">[email protected]</a> or contact
us by post at:



Fluencify AB 
Solparksvägen 3 
Solna, Stockholm 16954 
Sweden


<h2 id="request">
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
</h2>


Based on the applicable laws of your country or state of residence in the
US, you may have the right to request access to the personal information
we collect from you, details about how we have processed it, correct
inaccuracies, or delete your personal information. You may also have the
right to withdraw your consent to our processing of your personal
information. These rights may be limited in some circumstances by
applicable law. To request to review, update, or delete your personal
information, please visit:
<a href="mailto:[email protected]">[email protected]</a>.