PRIVACY POLICY
Effective Date : 14th February, 2024
Flutrr Digimate Private Limited, India, a private limited company having its registered office at Suite No. 1209, Merlin Infinite, 12th Floor, DN 51, Sector V, Saltlake, Bidhannagar 700091; is the owner of the domain flutrr.com / Flutrr (App).
We at Flutrr value your trust and confidence in the Site/App. That is the reason we put emphasis on highest standards for user information and privacy.
This Privacy Policy is a legally binding document between you and Flutrr. The terms of this Privacy Policy will be effective upon your acceptance of the same (directly or indirectly in electronic form, by use of the Site/App or by other means) and will govern the relationship between you and Flutrr for your use of the Site/App.
This Privacy Policy describes how your personal information is collected, used, and shared when you access Flutrr. The Policy is applicable to the Site and the App. This Policy applies to all Flutrr Users.
It is your duty to familiarize yourself with this Policy and ensure adequate compliance with it. You may be required to provide personal information at several different points on our Site. By accepting the Policy at the time of registration, you expressly approve and consent to our collection,storage, use and disclosure of your personal information as described in this Policy.
By using the Site/App, you agree to the terms and conditions of this Policy.
IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND SITE/APP. CONTINUED USE OF THE SERVICES AND SITE/APP CONSTITUTES YOUR FREELY GIVEN, SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL INFORMATION BEING PROCESSED PURSUANT TO THIS POLICY.
INFORMATION WE COLLECT AND IT’S USAGE :
Flutrr asks for User’s personal information such as email ID, mobile number, name as on facebook/gmail, date of birth, gender, images of the user, along with optional information such as educational qualification and employment status when the user registers with the Site. Users’ location is collected for providing better services to the Users.
Users can view this data on their profile anytime by logging in to their Fluttr account. Other users can see a user’s data when they login to their Flutrr, only to the extent that a user chooses to display.
The content that the User provides for the other User’s to view is at his/her own discretion. It is the User’s responsibility to use content of genuine and legal nature for his/her profile and communication with the other Users on Flutrr. If any content is reported by a User to be in violation of the above, Flutrr can choose to either block or terminate the account.
All information collected at the Site to become a registered user is obtained purely for providing the Services (please review the Terms and Conditions) and to improve the quality of your experience from the Services.
This privacy Policy discloses the privacy practices of Flutrr applicable to the handling of the information collected at the Site.
The user information collected at the Site is of two categories, Personally Identifiable Information and Non-Personally Identifiable Information. Personally Identifiable Information of the u ser can be specifically used to identify the user as an individual whereas, the Non-Personally Identifiable Information does not identify the user individually. Specifically, Flutrr uses the information collected at the Site for providing high quality Services and suggesting and recommending matches best suited for the user, processing payments, assessing user preference and compatibility aspects. All information collected on the Site could be used to resolve disputes, troubleshoot problems, collect receivables, measure gauge for surveys on User interest in the Site, inform User about promotions and offers, detecting fraud and other criminal activity, to enforce Terms and Conditions and other related policies.
By registering with the Site and consenting to Terms and Conditions and related policies at the Site, User agrees and confirms his/ her consent to providing Flutrr this information, which is lawful, necessary and permissible. Our products or services may include third-party products or services. When you use these products or services, they may also collect and use your information to serve you wherein such use and collection by third parties will be governed by their respective privacy policies. User at all times has the right to withdraw consent by communicating it to Flutrr or discontinuing use of the Site and Services offered by Flutrr. Users can also permanently delete their flutrr accounts themselves. Upon the User opting outing to withdraw such consent Flutrr will not be under any obligations to provide the Services nor will it be liable for the Services provided till then.
SOURCE OF COLLECTED INFORMATION:
- Log Files. Every time the User visits the Site, Flutrr servers automatically gather information from User browser (such as IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. This information provides an idea of which parts of Site the User visits. Log files are not shared externally.
- Cookies. "Cookies" are used to keep track of some types of information. These are very small files placed on user’s computer, which allow Flutrr to count the number of visitors to the Site and distinguish repeat visitors from new visitors. Cookies allow Flutrr to save user preferences and track user trends. Please bear in mind if the user’s browser is set to reject all cookies, the User’s experience may not be optimum and the Site may not function properly. Cookies are not linked to any Personally Identifiable Information and Users who refuse cookies assume all responsibility for any resulting loss of functionality.
- Mobile Analytics. Mobile analytics software could be used to allow Flutrr to better understand the functionality of our mobile software on User phone. This software may record information such as how often the User uses the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. This information is not linked to any Personally Identifiable Information.
- Payment /Purchase Information. To process payment/ purchases, Flutrr may require User name, phone number and email address. Such information is used primarily to process User order or as otherwise described herein. Flutrr adheres to strict security guidelines with respect to the storage, possession and handling of such information and protecting it against unauthorized access. It is clarified that Flutrr does not store User’s credit card information. User transaction on Flutrr is authorized and being processed by Google Play Billing and Razorpay Billing. Thus, all information related to credit/ debit card is stored/ held with only our authorized payment gateways. Flutrr, handles the information only in accordance with the provisions of the applicable law as made applicable from time to time and only for the duration lawfully required, thereunder.
- E-mails and Telephone Calls. User e-mail address is required while registering for the Services. e-mails are used for both transactional (e.g., confirmation for registration with the Site, credits, notifying of matches) and promotional (e.g., newsletters, new services, special discounts, etc.) purposes.
- Mobile Device. If User has registered any mobile device or uses the mobile device to access the Site, then device information may get collected (such as mobile device ID, model and manufacturer), operating system and version information, and IP address.
- Demographic Data. Demographic data could be collected on the Site. This data is used to tailor User’s experience at the Site, showing content that which might interest them, and displaying the content according to their preferences. Some of this information may be shared with advertisers on a non-personally identifiable basis.
- Online Survey Data. Information may be shared periodically during any voluntary member surveys. Users are encouraged to participate in such surveys as it helps in improving the Services. Survey responses are not linked to personally identifiable information, and all responses are anonymous.
- Information Regarding Referred Friends. The Site encourages Users to refer a friend for the Services by unique referral links by Flutrr. No information shall be taken from the user of the referred friend.
- Blogging Facility. Flutrr has a blogging facility on the Site and the blogs on the Site may contain posts which are relevant to dating and relationships and is available to Users and visitors to the Site. Any information that is disclosed in the comments section of the blog section becomes public information and User is expected and confirms that the User shall exercise caution when deciding to disclose any Personally Identifiable Information. To request removal of personal information from any blog, User has to contact Flutrr at contact@flutrr.com.
- Use for Research. In addition to the uses outlined above, User agrees to allow Flutrr to use the information in an anonymised form, from User experiences to continue our research into successful relationships. This research, conducted by psychologists and behaviour research scientists on the panel of Flutrr may be published in academic journals. All responses are kept anonymous, and not published.
- Use for Verification checks. The User is aware that to continue to receive the Services offered at the Site, it has to undertake the mandatory verification checks. The User agrees that information provided for the verification check is true and correct and is being provided voluntarily with complete knowledge of the purpose of its use by Flutrr and its authorized third party expert Service Provider for such verification. The Verification Check is conducted solely for the purpose of providing a richer experience in the Services. The verification process is kept anonymous and confidential and not shared with any third party other than authorized entities of Flutrr.
DISCLOSURE OF YOUR INFORMATION
Disclosure to User’s Matches.
For providing the Services Flutrr will disclose User profile information and verification results to recommended/ Suggested matches. Photos and other profile information posted by User will be available for viewing. Flutrr includes the feature that enables the User to, at his discretion, to share its profile with matches to share User profile information, including photos, with members of their social network(s). User contact information is never shared with User matches.
Disclosure By Law.
User acknowledges and agrees that Flutrr may disclose information that theUser provides if required to do so by law, at the written request of any government or regulatory authority , or if in Flutrr’s sole discretion, believe that disclosure is reasonablefor the following reasons:-
- To comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law);
- If the data relates to -
- the sovereignty, integrity, or security of the state;
- a state’s friendly relations with foreign states;
- public order;
- 4. for preventing incitement to the commission of any cognisable offence relating to the above; or
- for investigation of any offence.
- protect or defend Flutrr’s, or a third party’s, rights or property;
- protect someone’s health or safety, such as when harm or violence against any person is threatened; or
- for investigative purposes.Information Transferred As a Result of Sale of Business.
- Fluttr may buy or sell assets and, depending on the transaction, User Personally Identifiable Information may be one of the transferred and acquired assets.
Indemnification
- The User agrees to indemnify Flutrr for any breach in confidentiality of the User’s Personal Information.
- If the User accesses Flutrr through a third-party platform the User indemnifies Flutrr against any data breaches that occur due to any acts of commission or omission from the third-party platform.
- To the fullest extent of the law, the User shall indemnify, defend and hold harmless Flutrr, its officers, employees, agents, representatives, consultants, and contractors from and against any and all loss, costs, penalties, fines, damages, claims, expenses (including attorney’s fees) or liabilities arising out of, resulting from, or in connection with the services.
Links to or Access from Other Sites
Users may be able to access account or content from third party sites, such as social networking sites, by way of various applications. The privacy policies and practices of such sites in connection with information User discloses on such sites may differ from that on the Site. User is encouraged to review the policies and practices of these sites to ensure that the privacy of the information User submits on their site does not conflict with and is consistent with how User wishes this information to be treated. Flutrr is not responsible for the privacy policies or practices or the content of any other websites that may provide access to, or be linked to or from, this Site, including that of any social networking sites and third party advertisers whose offerings require User to navigate away from this Site.
INFORMATION SHARING
- Flutrr does not rent, sell or share any personal or sensitive information of User other than as mentioned in this Privacy Policy, with any third party.
- We may share information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services. We also use Google Analytics to help us understand how our users use the Site - you can read more about how Google uses your information here:: https://www.google.com/intl/en/policies/privacy/.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. We use Cometchat Chat Service. You can read more about how Cometchat uses your information here: https://www.cometchat.com/legal-privacy-policy . We use Amazon Face Recognition and Google ML Kit services for selfie verification of Users. We use Google Cloud APIs, Facebook SDK, and Firebase..
- Flutrr may contain links to third-party websites such as bvastro.com over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
- If Flutrr is acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.
- We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
STORAGE AND SECURITY OF INFORMATION WE COLLECT
- Flutrr follows stringent security techniques and requirements for handling sensitive and personal information. These techniques and requirements are fully compliant with the guidelines set forth under applicable law. Flutrr servers are accessible only to authorized personnel. User information logged under the Terms and Conditions is shared with respective personnel only on a need to know basis and/ or for the purpose of completing a transaction and/ or to providing Services. All representatives handling information under these provisions are under contractual confidentiality obligation with Flutrr.
- We use third-party vendors and hosting partners, such as MixPanel, for hardware, software, networking, storage, and related technology it needs to run the Site. We maintain different types of logs: server logs and event logs. By using Flutrr, you authorize us to use your information in India.
- We have strict practices in place to protect the loss, misuse, and alteration of several data and information under our control.
- We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
- We only retain personal information for so long as it is reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We periodically review the basis and appropriateness of our data retention policy.
- While, Flutrr takes every step to safeguard the confidentiality of user personal information, by using the Site, user agrees and confirms that Flutrr is not liable for any disclosure due to errors in transmission or unauthorized acts of third parties.
- Notwithstanding anything contained to the contrary in this Policy, Flutrr will not be responsible for any loss, damage, or misuse of any personal information, if such loss is attributable to a Force Majeure Event. The term force majeure event shall mean any and every event that cannot be performed due to causes that are outside the control of the parties, including but not limited to natural calamities or disasters, computer hacking or other similar events that could not be evaded through the exercise of due care.
- We have systems in place for bi-annual data security audit to manage the processing of personal data and to determine whether that processing is carried out in accordance with the applicable laws.
GOOGLE PLAY BILLING & RAZORPAY (PAYMENT GATEWAYS)
When you subscribe to our services, the payment is processed through Google Play Billing and Razorpay (payment gateways) which stores your credit/debit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). The payment gateways shall be responsible for the financial transactions on Flutrr, including accepting your payment, renewal process and refund (if applicable). In this context, they will be responsible for collecting relevant financial information from you. We encourage you to review the privacy policies of the third-party providers before you use the third-party software. For more insight, you may also want to read the below mentioned policies of Google Play Billing and Razorpay.
https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB.
https://razorpay.com/privacy/.
CHILDREN’S PRIVACY PROTECTION
Flutrr is not designed for, or intentionally targeted at, children below the age of 18 years. It is not our policy to intentionally collect information or maintain data about anyone under the age of 18. If you learn that anyone younger than 18 has unlawfully provided us with personal information, please contact us at [insert email id] and we will take steps to delete such information.
OPT-OUT PROVISIONS
Users can delete their Flutrr profiles anytime from the app settings. The User’s information will be deleted from Flutrr databases within 15 days from account deletion.
However, this information may remain in archives even after deletion or termination of User account as required by law and the handling of the same is in accordance with the provisions of the applicable law and as intimated by the government agency from time to time.
HOW WE PROTECT YOUR INFORMATION
Flutrr follows stringent security techniques and requirements for handling sensitive and personal information. These techniques and requirements are fully compliant with the guidelines set forth under law. Flutrr servers are accessible only to authorized personnel. User information logged under the Terms and Conditions is shared with respective personnel only on need to know basis and/ or for the purpose of completing a transaction and/ or to providing Services. All representatives handling information under these provisions are under contractual confidentiality obligation with Flutrr. While, Flutrr takes every step to safeguard the confidentiality of User personal information, by using the Site, User agrees and confirms that Flutrr is not liable for any disclosure due to errors in transmission or unauthorized acts of third parties.
CHANGES TO THIS PRIVACY POLICY
We are constantly looking for new ways to improve Flutrr and we may unilaterally update this Privacy Policy from time to time. When there is a significant change in this Privacy Policy, you will see a pop up in the app which you will have to accept before you can continue to use Flutrr.
Grievance Redressal
To address the grievances of the users, Flutrr has set up a Grievance Redressal Forum. In case you are dissatisfied with any aspect of our Services, or you may contact our Grievance Redressal Officer, Mr. Gaurav Pathak at support@flutrr.com. We assure you a time-bound response not exceeding one month from the date of your complaint..
CONTACT US
For any query, you can write to us at support@flutrr.com.
We reserve the right, at our discretion, to make changes to the terms of use and privacy policy at any time. The most updated version is available on our App and Website at all times. Please check the terms of use and privacy policy periodically for changes as all modifications are effective upon publication. Continued use of the Flutrr app and website after revision indicates the user's acceptance of the terms of use and privacy policy.