Privacy and Cookie Policy

Welcome to the Flippy AI Privacy Policy

Is this Privacy Policy for you? If you make or play games in Flippy AI, referred here as 'Flippy', experiences, this Privacy Policy is for you, whatever your age and wherever you live. It’s also for parents or guardians of users under 13 years old. This Policy covers the Flippy Services.

What is in this Privacy Policy? This policy describes the rights you have regarding your Personal Information. It explains that you can control what happens to the information that can identify you - like your name, where you live and your email address. In this Privacy Policy, we’ll also tell you when and how we use your information about you – including how we collect, record, organize, store and share it. Depending on where you live, you may have different rights or choices for managing your Personal Information, which this Policy will describe later on. In the event of a conflict between the information in Sections 1-5 of this Policy and the location-specific information in Section 8, the information in Section 8 shall prevail.

Where does this Privacy Policy apply? If you’re using Flippy, you’re in the right place. Here’s where you can learn about keeping your information safe. Using Flippy includes using: websites with a Flippy.com address. But if you leave our services, this Privacy Policy no longer applies. We’re not responsible for what you see on other websites or apps or for their privacy policies, even if you’ve linked to them from our website or app. When you go to another site or app, we may show you a message telling you that you’re leaving Flippy. Before moving on to the rest of the Privacy Policy, when you see certain terms in this Policy, some of them have specific meanings. “Children” or “Child” means any user under the age of 13 “Minor” or “minor user” means a user of the Services who is under the legal age of majority in their jurisdiction or state of residence “Personal Information” means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier “Platform” means our Flippy platform, the ultimate virtual universe where imagination rules “Privacy Policy” or “Policy” means this Flippy Privacy Policy “Processing” means any operation which is performed on Personal Information, such as collecting, recording, organizing, structuring, storing, adapting or making any kind of disclosure or other use “Service” means any service or application offered by Flippy, such as allowing users to develop Platform experiences, connect with others, and use content created by you and other users. It includes websites on the Flippy.com domain, our Flippy mobile, virtual reality and consoles, the Flippy Player, the Flippy Studio, and our other websites, products, software, applications, content, data feeds and other services on which an authorized link to this Policy is posted Any other capitalized term that is not defined in this Policy is defined and has the meaning set out the Flippy Dictionary. In the event of a material or perceived conflict between the English version of this Policy and translations into other languages, the English version shall control..

Are you Under 13 or responsible for an under-13-year-old?

If you’re under 13 years old, your access to certain features will be restricted in the interest of protecting your Personal Information. Flippy is especially committed to protecting the privacy of children. This part of the privacy policy is just for you.

First, get the go-ahead. If you’re under 13 years old, please get permission from your parent or guardian to use Flippy. You shouldn’t use our Services without their go-ahead.

No matter how old you are, Flippy communication settings allow you to control who can interact with you, for example, by only allowing interactions with friends or not allowing any interactions at all. You can also restrict your account, which turns off chat and public commenting and limits an account to certain filtered experiences on Flippy. Parents and guardians – we recommend you supervise your child whenever they’re interacting on Flippy. We’ve got some tools to help – you can learn about Flippy’s safety features here.

Information we collect if you’re under 13 years old. If you’re under 13 years old and create an account, we ask for some information (which is non-personal information, as defined by COPPA) to let you use Flippy. We’ll collect: your username (required). We need this to create your account and run the Flippy Service. We don’t use your username to identify you outside of Flippy your password (required). We need this to log you in to your account and to run the Flippy Service your date of birth (required). We’ll use this information to make sure your account has certain default settings intended for your age your gender (optional). We will use this information to customize your experience For additional account security and parental controls, you have the option to provide a parent’s or guardian’s email address in account settings or during logout. Children are encouraged to provide a parent’s email address, but are not required to do so to create an account. Parent email addresses (which is the only personal information as defined by COPPA we collect from child accounts) are collected for the security and integrity of your account and the Flippy platform. We may use your parent’s email address to communicate with them about your account, like asking them to review your account.

We don’t want more Personal Information If you’re under 13 years old, we will only ask you to tell us the information we need to set up or protect your account. If you give us more of your Personal Information, we will: delete any additional Personal Information we’ve collected from you (unless the law requires us to keep it), cancel your account, or turn on age-appropriate protections on your account When users publish anything in our public and comment areas (for example, chat, forums, group walls, personal posts), we filter it and remove: Personal Information like addresses, emails, phone numbers attempts at phishing (this is when someone tries to trick you into giving out Personal Information) offensive words, adult or suggestive content To provide the filtering above, we use human and automated checking to the best of our ability based on available technology – but like all filtering technology, these systems aren’t 100% effective.

Please ask us if you want to make privacy-related changes You can request that Flippy make changes to your child’s account or allow you to review, delete, or prevent the further collection or use of Personal Information from you or your child. To make a request, please fill out our Customer Support Form. In the US and want to know more? We comply with the Children’s Online Privacy Protection Act (“COPPA”). To learn more about COPPA, you can visit the US Federal Trade Commission’s COPPA website: https://www.ftc.gov/news-events/topics/protecting-consumer-privacy-security/kids-privacy-coppa You can also learn more about COPPA by looking at this simple guide from the kidSAFE Seal Program – www.kidsafeseal.com/knowaboutcoppa.html

When we collect your information

Setting up a Flippy account Your first step to joining a Flippy experience is to set up a Flippy account. We’ll ask you to create a unique username and password so you can log into your account and access features on Flippy. We also ask you for your birthday and gender (gender is optional) so we can customize your experience on Flippy. Eligible users may set their account's display name to contain certain Personal Information.

Three key rules for signing up: Do not use your own name or other Personal Information in your username. Do not pick a password that’s easy to guess. You may share your password with your parent or guardian, but do not share it with others. We don’t use your username to identify you outside of your activity on Flippy.

Why we ask you for an email address: Once you have an account, you can add your email address (or your parents’ or guardians’ email address if you are under 13) in case you need to reset your password. We might ask for your email to verify your identity or enable additional features. The main reason we need an email address is for security because it is how we check to make sure accounts are authentic. You can change your email address anytime you want – if an email address is changed, we’ll send a notification email to the address that you used before. Sharing your p

Sharing your phone number If you choose to give a phone number, we’ll send you a text message asking you to confirm your number before you can log in. We will use your phone number for security and account access, including to recover a lost or forgotten password or log in via mobile. You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Flippy or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. Additionally, with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Flippy. You will be recommended with your contact name as stored on your friends’ devices, which may also include your real name. If you do not want us to use your phone number to be found by your friends on Flippy, please do not activate this feature or deactivate it at any time. Please note that the Discoverability feature may not be available in certain locations. We do not ask for your phone number if you are under 13.

Asking questions or getting technical support We collect your email address (or your parents’ or guardians’ email address if you are under 13), username, and any other details you give when you: contact customer support report a problem ask for technical support ask us questions or give us comments We use this information to answer your questions and to give you the support or help you ask for. For users under 13, we communicate with your parent or guardian when sending our responses. We retain records of technical support questions for a limited time for internal use only, such as to answer additional questions about your account.

Using Flippy features We may use Personal Information when you use certain Flippy features. To provide access to certain features, we may use your email address and other information you provide to us, such as your verified date of birth. Third-party features such as social media add-ons (users 13 and older) You can use third-party features like social media widgets, share buttons, and login features. These features may include social plugins from Google, Facebook, Twitter, or other platforms. In these cases, the third party’s terms, conditions and privacy policies apply. When you use these features: we may be able to access or use information on your social media accounts information about how you use Flippy may be shared posted on your profile on those platforms If you use your Flippy ID to sign in to a non-Flippy website or service, and later delete your Flippy account, you may lose access to that website or service.

Interacting with our experiences To improve your experience and ensure safety, we collect information about how you interact with the Services and we connect this information with your account. For example, we may: collect information from your game state to detect violations of our Terms and to improve our ability to detect such violations. collect information about the games you are playing to give you similar recommendations. share information like your username and transaction details to the UGC creator or subsequent owners, if you acquire a limited item if you purchase, share, trade, or otherwise engage in a transaction involving UGC, collect information from your device through cookies - see “Cookies and Similar Technologies”.

Taking part in research If you choose to participate in research or surveys, these surveys may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for Personal Information.

Advertising To market Flippy’s Service to new and existing users, we use Personal Information like: IP addresses information on users’ browsers or operating systems, including language settings and general location information usernames or user IDs If you choose to create an Ad Account, we may collect additional information to create your account such as name, email, address, business and/or tax information. The purpose of collecting this information is to provide the ad account and comply with applicable laws, including tax laws. We do not collect or use Personal Information about users under the age of 13 for marketing purposes.

If you’re a developer or creator To take part in the Flippy Developer Exchange Program, you must give us an IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers). We may also ask you to verify your identity by providing a government-issued photo ID through a third-party vendor. This feature is only available to users who are 13 or over. For more information, please visit our Developer Exchange Terms of Use.

Other purposes for collecting your information We also use Personal Information for these general purposes, as permitted by law, in addition to the purposes listed above: To let you manage your account and our services To allow you to manage your Flippy account or update your settings To communicate with you about our Services To make things better for you To operate, maintain, personalize, and improve our Service To research relevant technologies To provide technical support or customer service To protect you by keeping our platform safe and secure To detect security issues, protect against malicious, deceptive or illegal activity, and prosecute anyone responsible for that activity To find and fix errors or bugs To give you access to features or limit your access to Flippy, as appropriate To protect our or our users’ integrity, safety or security To comply with the law and our policies To audit interactions and transactions, and carry out any other compliance tasks To comply with the law and our own Terms of Use, or any other restrictions we’ve put on your use of the Service You are under no obligation to provide Personal Information to Flippy when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features.

Cookies and similar technologies Information collected through cookies Like most websites, we use cookies and other standard internet technologies to help us make our services better. Cookies A cookie is a text file that’s put on your computer or device when you visit a website. It lets the website remember what you do and any settings you choose (e.g., login information, language, font size). Cookies make your experience more convenient – for example, if the cookie remembers your log-in details, you won’t have to enter them again each time you visit the site. Some cookies last longer than others: Session cookies are deleted each time you close the browser Persistent cookies stay on the device for a defined period of time. A cookie set by the owner of the web server you are visiting is called a first-party cookie and cookies set by owners of other domains are called third-party cookies. Pixel Tags/Web Beacons A pixel tag or web beacon is a piece of code that tells its owner what you do on a web page. Pixel tags provide information like which web pages you visited or which ads you clicked on.

How we use cookies We use technology like cookies to recognize you and customize your experience. We and any third-parties might use these technologies whenever you visit our sites or use our Services. We collect information about the devices and software you use, for example: the type of browser or device the website or source that linked or referred you to our services your IP address, device ID or other identifier that identifies your computer or mobile device – this cookie is not deleted when you close your browser the operating system of your computer or device These technologies allow us to: record and keep your preferences, account settings, and certain login information (for your convenience, e.g. to prevent you from needing to choose settings every time you visit, and security) collect information about how you use the Services, for example, how you downloaded our app or where you downloaded it from collect information on how software is used on your mobile device collect information about what features you use and how well our services work identify any suspicious activities so we can try to protect users from payment fraud and other inappropriate activities collect demographic information (eg, age, location, etc) perform similar functions. We use cookies or similar technologies only for the purposes given in this privacy policy. Your cookie rights in the EEA When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. For more information, see Section 8 below.

Your cookie choices For Flippy.com, click on the link in the footer at the bottom of the page to access your cookie options. For all other sites, please clear your cookies and refresh your browser to display the cookie banner to access its settings. Most web and mobile device browsers automatically accept cookies, but you can change your browser settings so that cookies are not accepted or you are warned before a cookie is set. Use information from browser companies to learn more about how they manage cookies: Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB, Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09, Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer, Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US, Safari (Mobile): https://support.apple.com/en-us/HT201265, Android Browser: https://support.google.com/nexus/answer/54068, Opera: https://www.opera.com/help. You can also learn more about cookies by visiting https://www.allaboutcookies.org/, which also tells you how to block or delete cookies that are already on your device. By blocking or deleting cookies used, you might limit your experience of the Service. You might not be able to log in or experience the Flippy. When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. For more details see Section 8 below.

To stop companies from tracking you on their websites You can ask us or a third party to disable advertising-related tracking on our websites. To disable this tracking, we or the third party may need to set an opt-out cookie on your browser. You may need to change your browser settings to accept cookies if you want to fully disable advertising-related tracking.

On our corporate websites or in job applications The parts of this privacy policy that are about experiences or give information about users under 13 years old don’t apply to the corporate websites. If you contact us about job opportunities, we may ask for your name, email address and employment details. Or you may send us a CV or job application with this information. We have the right to use this information to send you corporate-related information to you or respond to your job application. If you engage with Flippy in an immersive space for prospective employees, such as the Flippy Career Center, such a space may be recorded in order to provide the experience. Our corporate websites give general company information to any user that visits them – they use the domain names, corp.Flippy.com, blog.Flippy.com, and their subdomains. On these sites, we give information about the corporate side of Flippy, press information, career information, and other general audience information. Our corporate websites do not offer any experiences.

When we share your information

We do not sell Personal Information. Flippy does not sell Personal Information about you. However, we may share your information for a valid business purpose, as described below.

We may share Personal Information where necessary. When other companies need Personal Information to provide a service on our behalf We may share your information, including Personal Information, with other companies (known as third-party agents, contractors, or service providers). We hire these companies to perform services for us. These companies are only allowed to use the information we share to complete the relevant tasks. They are not allowed to use the information we share for any other purpose, including selling Personal Information. We make sure that all companies that we share information with are capable of looking after the information properly. Personal Information collected through the SMS program, won’t be shared, sold or rented to third parties. Here are examples of the services that we might rely on other companies to provide, and examples of the companies that we are likely to share information with. Account integrity and security services (e.g., Veriff, Persona, Arkose Labs); Analytics services (e.g., Google LLC); User acquisition services (e.g., AppsFlyer); Community filtering and moderation services (e.g., CommunitySift); Customer support services (e.g., Zendesk); Surveys and promotions (e.g., Reach3); Social media log-in services (e.g., SAP Customer Data Cloud); Billing and payment services (e.g., Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla) Hosting and content delivery services (eg, AWS, Equinix, CenturyLink, YouTube, Vimeo).

When creators need Personal Information to improve your experience The creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators. We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in.

For legal reasons or to help prevent a crime We may share your Personal Information, as permitted or required by law, if: necessary to comply with a judicial proceeding, court order, or other legal process served on Flippy law enforcement agencies, regulators, or other public agencies (including schools or children services) request that we share it we believe that disclosing the information may prevent a crime a law requires us to share it

To help ensure safety and security We may share your Personal Information if we believe that sharing would: help an investigation into public safety protect the safety of a child using Flippy help to protect the security or integrity of our Services.

If we need to protect ourselves against legal responsibility We may share your information if we believe that disclosing the information will allow us to take precautions against taking legal responsibility (liability) or to protect our rights.

If there is a transfer of rights in our business e.g., if we sell our business We may hand over rights to access your information, including Personal Information: as part of a merger, acquisition, sale of assets, or similar transaction if information is handed over as a business asset in an insolvency, bankruptcy, or receivership Where required by law, we will notify you and ask you to consent to such sharing.

We may share information that does not identify you In some circumstances, we share data that doesn’t identify you, for example: To comply with reporting requirements For any business or marketing purposes To help us and others understand how, when, and why users visit our sites and use Flippy. We may share non-identifying data of all users regardless of their age.

We’re not responsible if you share your own Personal Information If you’re 13 years old or over, you can share your Personal Information through chat, forums, messages or similar ways of sharing on our Service. Remember that anyone who uses these features will be able to see anything you share in this way. We are not responsible for how your Personal Information is used if you shared it yourself.

Do Not Track (DNT) signals Our Services do not respond to Do Not Track (DNT) signals. We do not track our users over time and across other websites to provide targeted advertising.

You can update or delete your Personal Information

If you want to view, correct, or delete your Personal Information, or if you want us to make another request about your Personal Information, please fill in the Customer Support Form. If you’re under 13 years old, please have your parent or guardian fill out the form. If Personal Information about you changes, or if you no longer want to use our service, you may correct, update, change, or close your account under your account settings or by contacting Flippy through the form above. We will respond to your request within a reasonable timeframe. See Section 8 for additional rights available to residents of certain states in the United States, the UK, Switzerland, the European Economic Area, and Brazil.

Looking after your information

Security measures We have security measures that are intended to protect any Personal Information or other sensitive information under our control from loss, misuse, or alteration. Though we cannot guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it. Sending or storing information on the Internet is not 100% secure, so we can’t guarantee the security of any information you share with us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

We’ll tell you if your privacy is at risk We may send you emails or other messages about security, privacy, and account management. If we learn about an incident that may qualify as a data breach under the law, we will notify you in accordance with the law.

How long we keep your information We may keep your Personal Information for specific purposes as long as we need it to fulfill those purposes, sometimes even if you’ve stopped using Flippy’s Services. When we no longer require your Personal Information, we will de-identify or delete the information. Here are the reasons we may need to keep your information:

For resolving problems We keep billing information and transaction histories so that we can resolve billing disputes or inquiries. We keep user account history to solve any customer service issues and to provide, improve, and develop our service.

To make our services safer We may keep information if it will help us make our Service safer and more secure, such as to stop bad actors who try to misuse Flippy.

For legal reasons We may keep information for legal reasons, like establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, exercising our rights, or complying with legal obligations.

Letting other users keep your information Other users may keep publicly shared content and virtual items on our platform (e.g., if you create a virtual shirt and then sell it to another user, the virtual shirt will be kept on the platform because the other user now possesses it).

Where we store your information Flippy is based in the United States. We send information we collect from you to our secure servers in the U.S. where we store and use it. This storage is necessary for us to process the information. We may also transfer information that we collect from you to our other offices and to the third parties mentioned in Section 4 of this Policy – these might be outside your region. Our agents or contractors may also use your information. The data protection laws of the U.S. or other countries may not be equivalent to those where you live. Wherever we transfer your Personal Information, we will take reasonable steps to ensure that your privacy rights continue to be protected. If required by applicable legislation, we rely on a valid international data transfer mechanism to enable cross-border data transfers.

Privacy Policy Changes and Updates

We update this Privacy Policy at times, so you should review this page regularly. We always publish the date of the latest version at the bottom of this page. If we make any major changes, we will let you know by email (if we have your email address or a parent’s or legal guardian’s email address) or by showing a prominent notice on this website or in app prior to the change becoming effective. If required by law, we will obtain your consent or the consent of a parent or legal guardian if any of these changes involve new material uses of your Personal Information not previously disclosed in this Privacy Policy.

Additional information based on where you live

If you are a California resident Your Rights as a Data Subject In accordance with California law, you may have the following rights: Access to/Portability of Personal Information. You can receive a copy of categories of Personal Information and specific pieces of Personal Information we have collected, used, disclosed, sold, or shared about you in the past 12 months, consistent with legal requirements. Residents also have the right to request the categories of Personal Information disclosed for a business purpose, the categories of sources from which their Personal Information was collected, our business or commercial purposes for collecting their Personal Information, and the categories of third parties to whom we disclosed their Personal Information. In addition, you may have the right in some cases to receive or have your electronic Personal Information in a portable format or transferred to another party. Correction. You can request correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction. Deletion. You can request we delete Personal Information we collect from you, subject to certain exceptions prescribed by law. Restriction of or Objection to processing. You can request restriction or object to the processing of your Personal Information, and you have the right to opt in or opt out of the sale or sharing of your Personal Information to third parties, if applicable, where such requests are permitted by law. Please note that, in the case of California residents, we do not currently sell or share Personal Information, as those terms are defined under the California Consumer Privacy Act and the California Privacy Rights Act. For that reason, we do not currently offer a mechanism for California residents to opt out of the sale or sharing of Personal Information. We have no actual knowledge of selling or sharing the Personal Information of minors under 16 years of age. Non-discrimination. You have the right to not receive discriminatory treatment by exercising your privacy rights. We do not discriminate against California residents who exercise their privacy rights. Please note that some of these rights can be exercised by updating your account within the Services, or you can contact us as set forth in Section 1 above for other requests. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request so that we can ensure you are the owner of the account making the request. Our California resident consumer request metrics for the previous year can be found here. For additional information related to your rights under California law, including information related to California retention periods, how you can exercise your rights, and more, please visit our full Flippy CPRA Privacy Policy.

US States State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California Additional information for California residents can be found in the “If you are a California resident” section of this Privacy Policy, above. Please also visit our CPRA Privacy Policy.

Colorado, Connecticut, and Virginia State laws provide residents in Colorado, Connecticut, and Virginia with certain rights, including the rights to: Confirm whether we process their personal information. Access, correct and delete certain personal information. Receive copies of their data in a portable format. Opt out of processing of Personal Information for targeted advertising, sales of their data, and profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise any of these rights, please complete the Customer Support Form. To appeal a decision regarding consumer rights, please contact us at privacy@Flippy.com. Please note that we may maintain and use de-identified data, as defined under applicable law, without attempting to re-identify the data.

If you live in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland Categories of Personal Information and Data Processing Purposes In the course of visiting our websites and apps, and/or using our services and products, we may process the following Personal Information subject to the legal bases mentioned below:

Setting up a Flippy account Username and password to create your account. The basis for processing this personal data is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). Email addresses and other information you provided us with for added verification and/or to enable certain features. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”) GDPR. Flippy has a legitimate interest in providing a safe and secure Service, especially to protect children. If you choose to provide a phone number, we will use the phone number for security and account access purposes, which will allow you to log in via mobile and recover a lost or forgotten password. You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Flippy or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”) and f (“legitimate interest”) GDPR. We have a legitimate interest in enabling you to use our Services via your mobile device, ensuring security, and preventing fraud. Additionally, with your explicit and informed consent, we may use your phone number to recommend you as a friend to others using Flippy. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”).

Purchases on Flippy Billing and payment information, when you participate in Developer Exchange or purchase virtual currency or premium subscriptions, including your name, billing address, credit card or other payment information and billing information. You may choose to save information such as your credit card number through a third-party payment provider; in such cases the information is not stored by Flippy; it is stored with the third-party partner. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). We may also retain transaction details and purchase and payment history. The legal basis for processing these personal data is our legitimate interest in being able to resolve subsequent billing disputes and inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

Posting content Comments or messages you post or transmit on Flippy via public chats, forums, group walls, personal post, etc. We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, Personal Information, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology. The legal basis for this processing activity is Flippy’s legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”). Please note that any Personal Information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The Personal Information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.

Asking questions or getting technical support Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support. This processing activity is based on your consent according to Article 6 sec. 1 sent. 1 lit. a GDPR and/or Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.

Using Flippy Features Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Flippy, and likewise, certain information about your use of Flippy may be posted to your profile on those platforms. The legal bases for this processing activity are Article 6 sec. 1 sent. 1 lit. a (“consent”). If you use your Flippy credentials to sign in to a third-party website or service, and later delete your Flippy account, you may lose access to such third-party website or service. When you request or agree to voice based services from Flippy, we may collect, process and store your voice recording to provide services and to improve our voice related services. We may use your voice recording for purposes such as training and improving our filter technology to increase the safety on our platform, except that we will not engage in training or product improvement with private server voice chat recordings of EEA users. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. a (“consent”) GDPR. We further have a legitimate interest Article 6 sec. 1 sent. 1 lit. f (“legitimate interest”) GDPR to provide moderation and increase the safety of our voice related services. When you request or agree to location-based services (users 13 years old and older), we may collect and track geolocation information so that we can offer services that depend on us knowing where you are. Examples are check-in, or personalizing content or advertising. We collect this information by using an identifier on your device or browser so that we can recognize you each time you return. To stop us collecting your location information, you can update your device settings, stop using the service, or uninstall our mobile apps. The basis for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). If you join our experiences on a VR platform, we will collect your physical movement information in order to replicate your movement in the experience. This information is only used to provide the Service and is not stored. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). If you join a virtual event hosted by a Creator, data such as your username, email, and Flippy user ID may be shared with the third-party platform that hosts events. Such data is used to allow you to log in to the experience. Your activity during a Creator Event is subject to the third party platform’s privacy policy as well as the Flippy Community Standards. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) to join an event and f (“legitimate interest”) GDPR to ensure the security and integrity of our service. Information required for additional features that require the use of your camera or upload content that contains your Personal Information. If you decide to use these features and upload content that require the use of your camera or upload content that contains your Personal Information, we will collect, process, and store that content only for as long as needed to accomplish the purpose of the feature. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). For more information, please refer to the Flippy Facial Animation Privacy Policy. Information required for other features or activities, which may be available to our users other than children. We may offer other features or activities on our Services from time to time, and you may be able to submit or upload Personal Information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). If you opt-in to the Contact Importer feature, you consent to sharing with Flippy the first and last names and phone numbers of your contacts in your address book on your mobile phone, either at the time you register for our Service or otherwise. We do so to help you connect with your friends on our Service. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). Interacting with our experiences. To improve your experience and ensure safety, we collect information about how you interact with the Services and we connect this information with your account. For example, we may collect information from a user's game state to detect violations of our Terms and to improve our ability to detect such violations; collect information from your search history to give you similar recommendations; share information like your username and transaction details to the UGC creator or subsequent owners, if you acquire a limited item if you purchase, share, trade, or otherwise engage in a transaction involving UGC. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”). We may use data collected from your interaction with our experiences for safety purposes on the basis of Article 6 sec. 1 sent1 lit. f ("legitimate interest").

Competitions, promotions, and research When you respond to or participate in voluntary research or surveys or studies. These surveys may collect information about your likes and dislikes, experience interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for Personal Information. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). Information relating to your participation in contests, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

Advertising To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process Personal Information such as IP addresses, information on users’ browser or operating system, including language settings, regional location information and user names or user IDs. The legal basis for the processing of this data is Flippy’s legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events, Art. 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”). When you choose to create an Ad Account, we may collect additional information for your account (such as name, email, address, business information, etc.) in order to create an account. The bases for processing this personal data is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”). We may also retain transaction details and purchase and payment history. The legal basis for processing these personal data is our legitimate interest in being able to resolve subsequent disputes and inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

If you’re a developer or creator Information required for participating in our Flippy Developer Exchange Program, like the IRS W-9 form (for U.S. taxpayers) or W-8 form (for non-U.S. taxpayers). The legal basis for this processing is Article 6 sec.1 sent. 1 lit. f GDPR (“legitimate interest”) with regard to U.S. law requirements. It is our legitimate interest to comply with the legal requirements, especially with regard to U.S. anti-money laundering laws.

Other purposes for collecting your information Login information, which may include your IP address, device type, username, password, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with our Service. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR. It is in our legitimate interest to guarantee the Services’ stability and security. Account information, e.g. information such as your name, username, login and password details, regional location information, user-generated content, contact details that you choose to provide to us, and other Personal Information that are used for participating in the Service we are offering. We process this information to provide our Services to you. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

Cookies and similar technologies We use cookies. Some of these cookies are necessary for the basic functioning of the website and therefore cannot be deactivated. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”) and Art. 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”) because we have a legitimate interest to guarantee the Services’ stability and security. We will use optional cookies only if you have previously consented to such use. When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”). In addition, you can also manage cookies using your browser settings. For further information on cookies and similar technologies see Section 3 above.

On our corporate websites or in job applications Information relating to a job application made by you, like your name, email address, employment details, CV, resume or other details of your employment history sent by you. We will process this information to process and respond to your job application. If you engage with Flippy in an immersive space for prospective employees, such as the Flippy Career Center, such a space may be recorded in order to provide the experience. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“necessary for entering into an employment contract with us”).

Automated Decision-Making Please note that we do not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

Personal Information of Children and Parental Consent Please note that when users under the age of 13 register for the Service, their account is automatically set to privacy-protective settings by default. This means that these users will not have access to certain features, such as social media plug-ins, some forms of third party advertising, and certain types of notification alerts. When a child creates an account on Flippy, we may process a username, password, birthdate, and gender (gender is optional). Separate from account creation, users may optionally provide a parent email address. We process this information to give the user access to the Service and to communicate with the parent about the child’s account (if a parent email was provided). For example, we may use the parent’s email to send an email notification about the child’s account and an invitation for the parent to review the account and update settings. We may use the birthdate the child provides when signing up for the Service to determine which features on Flippy the child should have access to and to determine when the child will turn 13 years old and can be given broader access to features on our Service. This processing activity is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). In general, we will not use or share account information (including Personal Information) from a child’s account except for the permissible purposes stated in this Privacy Policy, and, if required by law, only with the prior verifiable consent of a parent or legal guardian (Article 6 sec. 1 sent. 1 lit. a and Article 8 sec. 1 GDPR).

Data Sharing Flippy may share users’ information, including Personal Information like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Flippy’s behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions: Account Integrity and Security (e.g., Veriff, Persona, Arkose Labs); Analytics services (e.g., Google LLC); User Acquisition services (e.g., AppsFlyer); Community filtering and moderation services (e.g., CommunitySift); Customer support services (e.g., Zendesk); Surveys and promotions (e.g., Reach3); Social Media Log-in (e.g., SAP Customer Data Cloud); Billing services and payment gateway providers (e.g., Kount, Worldpay, PayPal, Incomm, Blackhawk, Google, Apple, Amazon, Windows Store, Xbox, Playstation, Meta Quest, Xsolla); and Hosting and content delivery network services (e.g., AWS, Equinix, CenturyLink, YouTube, Vimeo). The legal basis for this data transfer and processing activity is Article 28 of GDPR in conjunction with the data processing agreements we concluded with respective third-party agents. These agents and contractors are only allowed to use the information shared with them only for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes. Flippy takes steps to ensure that all service providers with access to Personal Information are capable of protecting the information we share with them. Further, the creators of the experiences you use or content you interact with will have access to your username, display name, user ID, game metrics, UGC transaction details, and your regional location (which we base on your IP address). We do not share your IP address with the creators. We provide creators with the regional location of players to determine their player base and make sure their experiences meet the legal requirements of the country you live in. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”), Article 6 sec. 1 sent. 1 lit. c (“compliance with legal obligation”) in compliance with the respective EEA or Member State law and lit. f (“legitimate interest”) GDPR. It is the creators’ legitimate interest to comply with non-EEA legal obligations.

Legal disclosure We may disclose Personal Information about you, including the content of your communications on the Service, to comply with legal process, including court orders and subpoenas, served on our Service. In addition, we also may disclose Personal Information about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if such disclosure may (i) prevent the instigation of a crime, (ii) facilitate an investigation related to public safety or protect the safety of a child using our Service, (iii) protect the security or integrity of our Service, or (iv) enable us to take precautions against liability or to protect our rights. The legal basis for such disclosure is Article 6 sec. 1 sent. 1 lit. c (“compliance with legal obligation”) in compliance with the respective EEA or Member State law and lit. f (“legitimate interest”) GDPR. It is our legitimate interest to comply with the legal requirements of U.S. law. Further, we have a legitimate interest in these purposes.

Storage and international transfer of your Personal Information Flippy is based in the U.S. Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information. Some of our agents and third-party service providers are located outside the European Economic Area, e.g. the United States. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence. Wherever we transfer your Personal Information, we will take reasonable steps to ensure that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.

Your rights as a Data Subject If you are a user based in the European Economic Area, you may be entitled to exercise some or all of the following rights: Request (i) information whether your Personal Information is retained and (ii) access to or duplicates of your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the data recipients as well as potential retention periods; Request rectification, removal or restriction of your Personal Information, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn; Refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time; Object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing; Object to the use of your Personal Information for direct marketing at any time; Request (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side. Where technically feasible you shall have the right to have the Personal Information transmitted directly from us to another controller. You may (i) exercise the rights referred to above, (ii) pose any questions, or (iii) make any complaints regarding our data processing by contacting us under the contact details set out above in Sec. 1. Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators.

Schools:

Flippy is available for schools. Contact your school's IT department and tell them you are interested!

For more info: sales@flippy-ai.com.

Support:

© 2024 Flippy AI. Irvine Ca.