Privacy Policy

Welcome to Flamo’s Privacy Policy! We take your privacy seriously and strive to make this policy clear, engaging, and legally thorough. Whether you're finding your perfect match or exploring our app, this document explains what personal data we collect, how we use it, and what rights you have. We comply with global regulations, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and the UAE Federal Decree-Law No. 45 of 2021 (PDPL). If you have any questions, please feel free to contact us.

1. Who We Are

Flamo is operated by Arbiella Group FZC, headquartered in Sharjah, UAE. We abide by UAE Federal Law No. 45 of 2021 for Personal Data Protection. If you live outside the UAE, your data may be processed in other regions, and we ensure full compliance with the applicable legal frameworks.

2. Where This Privacy Policy Applies

This Privacy Policy applies to all services provided under the Flamo brand, including our app, website, events, and other services ("Service"). It does not apply to third-party platforms or services that may interact with ours unless explicitly stated. Where specific services require additional terms, those will be provided separately and will supersede this Privacy Policy for that service.

3. Data We Collect

To help you find meaningful matches and enhance your experience on Flamo, we collect various types of data. This includes:

3.1 Data You Provide

• Account Information: When you create an account, we collect your phone number, email address, date of birth, and other basic details.
• Profile Information: This includes the information you share on your profile, such as your name, gender, age, preferences, interests, photos, videos, and more. This may also include sensitive data such as sexual orientation or political beliefs, and by sharing this information, you consent to its use under this policy.
• Content: Any photos, messages, videos, and audio recordings you share within the app or in chats with other members.
• Purchase Information: Details of transactions made through the app, including payment methods, dates, and amounts.
• Survey and Marketing Data: When you participate in surveys or marketing promotions, we collect feedback and information required for participation.

3.2 Data Automatically Collected

• Usage Data: This includes login times, interactions with other users, searches, and engagement with our features.
• Device and Technical Data: We collect technical data from your device to ensure optimal security, performance, and user experience. This includes your IP address, device identifiers such as IMEI and MAC addresses to prevent fraud, operating system details, and device model information to troubleshoot and improve functionality. Diagnostic data from crashes, network type, and connection speed are also collected to enhance stability and service quality.
• Cookies & Tracking Technologies: Cookies and other technologies like SDKs or browser tracking help us improve our service and deliver relevant ads. You can manage cookies through our Cookie Policy.
• Geolocation Data: If you enable location services, we collect geolocation data to help show nearby matches. This can be disabled in your settings.

3.3 Data From Third Parties

• Social Media: If you choose to link Flamo to your social media accounts (e.g., Facebook or Google), we may collect data from these accounts, such as profile pictures or friend lists.
• External Sources: Occasionally, we may receive data about you from third-party partners to help improve security or verify your identity.

3.4 Additional Data Collected with Consent

• Face geometry data: You can opt to use certain features, such as Photo Verification or Photo and ID Verification, which involve collecting face geometry data. In some regions, this may be classified as biometric data.
• ID Data: You may share a copy of your government-issued ID to verify your identity.

4. Why and How We Use Your Data

Flamo processes your personal data for a range of purposes, outlined below:

• Service Provision: We use your data to create and manage your account, suggest potential matches, and enable features like messaging, uploading photos, and profile management.
• Service Improvement: Your data helps us analyze and improve our services, develop new features, and optimize overall performance. This includes testing new technologies, conducting research, and improving customer care.
• Safety & Security: We process data to detect and prevent fraud, monitor suspicious activities, and ensure users adhere to our terms of service. We take security measures to verify identities and safeguard against fraud.
• Marketing & Promotions: With your consent, we may send marketing communications, including personalized ads. We also measure the effectiveness of our marketing campaigns across platforms to improve targeting and engagement.
• Legal Compliance: We use your data to comply with applicable laws, including GDPR, CCPA, and PDPL. This includes responding to law enforcement requests, reporting illegal activity, and addressing any legal claims.
• Use of AI: We apply AI to enhance user experience, improve match recommendations, and analyze user behavior to personalize content.

5. How We Share Your Data

Flamo shares your personal data under specific circumstances to provide you with services, ensure security, and comply with legal obligations. Here’s how and with whom we share your information:

• With Other Members: Information like your profile details, photos, and mutual matches are visible to other users. This allows members to interact and match with one another. You can control the visibility of some of this data within your privacy settings.
• With Service Providers: We share your data with trusted third-party service providers that assist us in delivering our services. These include data hosting providers who store and maintain our databases securely, analytics services that help us understand how our app is used and optimize user experience, customer support providers who assist in resolving issues, and payment processors who handle transactions and ensure secure payment methods. These partners only access the data necessary to perform their services.
• With Affiliates: Flamo may share your data with other entities within the Arbiella Group FZC or its affiliated companies. This helps us process your information for internal administrative purposes, implement safety measures across platforms, and improve your experience across services offered by our affiliates.
• With Advertising Partners: We may publish ads from third-party advertisers or promote our own services on third-party platforms. To make these ads more relevant, we may provide third parties with certain information about you, such as your email address, advertising identifiers, or phone number. These identifiers can be transformed into anonymous tokens that cannot be traced back to you personally. Our advertising partners may use these tokens to either exclude you from certain marketing campaigns or target ads to users with similar profiles, based on your interests and app usage.
• For Legal Purposes: We may disclose your data to law enforcement, regulatory bodies, or other authorized entities if required to comply with legal processes. This includes court orders, subpoenas, or search warrants, as well as requests to aid in preventing or detecting crime, protecting the safety of any individual, and establishing, exercising, or defending legal claims. We ensure that any such disclosures are done in accordance with applicable laws like GDPR, PDPL, or CCPA.
• In the Context of Mergers or Acquisitions: If Flamo is involved in a merger, acquisition, restructuring, or sale of assets, your data may be transferred as part of the transaction. We will notify you before such a transfer, and the receiving entity will be required to follow the same privacy practices outlined in this policy.
• When You Use Sharing Features: You may choose to share your profile or other members’ profiles with people outside of Flamo using our sharing functionality. Please be mindful of who you share this information with, as it can be accessed outside the platform.

6. Your Rights

Depending on your location, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Update or correct inaccurate information.
• Deletion: Request the deletion of your personal data.
• Objection: Object to the processing of your data for marketing or profiling.
• Data Portability: Receive a copy of your data in a readable format.
• Consent Withdrawal: You can withdraw consent at any time by adjusting your account settings or disabling device permissions (e.g., access to contacts, photos, advertising IDs, location, or push notifications). Note that withdrawing consent may affect the functionality of certain services. Feel free to contact us for more details.

To exercise any of these rights, contact us at contact@flamo.io. We will respond within the legally required timeframes based on the laws of your region (e.g., GDPR, PDPL, CCPA).

7. Data Retention

We aim to provide a seamless and secure experience while ensuring we retain personal data only as long as necessary for legitimate business purposes, compliance with legal obligations, or protection of our rights. If you stop using our service or decide to close your account, we implement the following data retention measures to protect both your privacy and the safety of our community:

7.1 Active Accounts:

We retain your data for as long as your account is active and you continue to use our services.

7.2 Inactive Accounts:

If your account remains inactive for 24 months, we will deactivate and ultimately delete it. However, before permanent deletion, you will receive notifications, giving you the opportunity to recover the account if desired. Once deleted, your data is erased from our live systems.

7.3 Retention After Account Closure:

Upon account closure, your profile will no longer be visible to other members, but we retain certain data as follows:

• Safety Retention Window: We implement a three-month safety retention window after account closure to investigate any unlawful or harmful behavior, in line with our legitimate interest and those of potential third-party victims. If your account was banned for violating our Terms of Service, we retain the data for one year following the ban to prevent future breaches.

7.4 Legal Obligations:

To comply with legal requirements and obligations, we maintain certain data for longer periods:

• Transaction Data: Retained for 10 years to meet tax and accounting regulations.
• Traffic Data / Logs: Stored for one year to comply with legal data retention requirements.
• Consent Records: Retained for five years to demonstrate compliance with applicable laws regarding consents you provided.

7.5 Customer Care and Dispute Handling:

For customer support and legal protection, we retain communication records and related data for the following periods:

• Customer Care Communications: Retained for six years from the date of the communication to provide ongoing support and protect our rights in case of disputes.
• Past Account Information: We store data on the existence of past accounts and subscriptions for three years following the closure of your last account for accurate financial reporting and forecasting.
• Profile Data: Retained for one year after account closure in anticipation of any litigation or legal claims.

7.6 Retention for Legal Claims or Disputes:

In case of outstanding or potential legal issues, claims, or disputes, we may retain your data beyond the standard retention periods:

• Legal Proceedings: If we receive a valid legal subpoena or request, we are obligated to retain relevant data to comply with legal processes or to establish, exercise, or defend against legal claims.
• Retention for Active Disputes: We may retain data related to ongoing or anticipated disputes for as long as necessary to protect our legal interests and those of our community.

7.7 Data Anonymization:

Where legally permitted, we may retain and use anonymized data, which cannot identify you, for purposes such as improving our services, enhancing security, and developing new features or technologies.

7.8 Data Security Measures:

We take appropriate technical and organizational measures to ensure that your data is stored securely during the retention period. These measures include encryption, access controls, and appropriate measures to protect data breaches. If a breach occurs, users will be notified as required by applicable laws.

7.9 Your Data Deletion Rights:

If you wish to have your data deleted before the retention period ends, you can request this by contacting us at contact@flamo.io. We will process the deletion request in compliance with applicable laws and regulations.

8. Children’s Privacy

Flamo is intended only for users aged 18 and above. We do not knowingly collect data from anyone under 18. If you become aware of a minor using our service, please notify us immediately, and we will take action to remove the account.

9. Changes to the Privacy Policy

We may update this Privacy Policy as needed to reflect changes in our practices, the law, or new features on our service. If significant updates occur, we will notify you through the app or via email before the changes take effect.

10. Contact Us

If you have any questions about this Privacy Policy or need to exercise your rights, you can reach us at:

Email: contact@flamo.io