Privacy Policy

This privacy policy applies to App Flirtfox.

Short version: Your privacy is very important to EasyWeb s.r.o. Therefore, we will use your complete data only for the operation and optimization of our product. We will never give your sensitive data such as name, profile picture or e-mail address to third parties for advertising purposes.

If you would like to take precautions against the use of data for advertising purposes, you can deactivate personalized advertising in the app settings under privacy and in your device settings. On an Apple device, you can do this in the iOS settings under "privacy" -- "advertising" by activating the option "no ad-tracking" or on a device with android system under "Google settings" (or "Settings" and therein "Google"), then click on "show" and click on the button at "deactivate interest-based display". You can always delete the IDFA or the advertising ID in the device settings ("reset Ad-Id"). In this case a new identification number will be created, which will not be merged with the previously collected data. On a Huawei device, you have to do the following: Swipe up on the home screen, tap the gear icon, and turn off the "Magazine unlock" feature. If you do not want to disable the option, you can easily check your subscription in "Magazine unlock". You should check the "Travel" and "Transportation" sections to see if they are checked or unchecked. If you find them there, you should simply uncheck them.

The long version:

Introduction

EasyWeb s.r.o., Husovo Namesti 1, 267 12 Lodenice, Czech Republic (hereinafter "EasyWeb s.r.o." or "we/us") operates the mobile app Flirtfox (hereinafter: "Flirtfox App" or "Flirtfox"), which is available for download for various operating systems, a platform for chatting, getting to know and meeting other people and is the responsible entity.

The service offered is a freemium model, whereby the user of Flirtfox (hereinafter: "user" or "you") can create a profile (hereinafter: "user profile") free of charge via the Flirtfox app, upload pictures and exchange information with other users and their user profiles if interested. The user has the opportunity to take advantage of the functions of a free membership of Flirtfox. Flirtfox also offers a paid premium service (VIP membership), which enables the user to access additional, exclusive functions.

Your data will be collected, processed and used according to the currently valid national and EU legal requirements.

This privacy policy clarifies the handling of personal data. Personal data is individual information about personal or factual circumstances of a certain or determinable natural person. This includes, for example, name, birthday, telephone number, but also e-mail address and usage data, such as IP address. Furthermore, the data protection declaration provides information about which data is collected, stored and processed and how EasyWeb s.r.o. ensures the protection and security of personal data.

EasyWeb s.r.o. does not require a clear name. The user can also enter a pseudonym instead of a name. For individual parts of Flirtfox - for example, if you receive money from us - it may be necessary for tax reasons to provide us with your name, address and nationality. In such cases we will inform you separately.

1. How is my data collected, processed and used when downloading the Flirtfox app?

1.1. Download the Flirtfox App

When you download the Flirtfox app, the necessary information is transferred to the respective app store operator. Depending on the App Store, this information may include, for example, the e-mail address or customer number of the App Store user of the respective App Store, the time of the download and an individual device ID number. However, EasyWeb s.r.o. has no influence on this data collection and is not responsible for its processing. The corresponding data protection declarations/ settings of the respective App Store operator apply.

EasyWeb s.r.o. processes the data provided by the respective app store operator to the extent necessary for downloading the Flirtfox app to the end device.

1.2. Installation and permissions

EasyWeb s.r.o. requires various access options and information for the technical functioning of the Flirtfox app and for providing the services offered with the Flirtfox app.

Depending on the operating system, permission to access individual functions and information is requested during the installation process. The access permissions include location, notifications and mobile data.

These authorizations can be partially withdrawn manually in the settings of the end device. However, it must be taken into account that the Flirtfox app can only be used to a limited extent or not at all without the corresponding approvals. Depending on the app version, permissions are queried before or after installation.

2. How is my data collected, processed and used when I visit the Flirtfox app without creating a user profile at Flirtfox?

According to this privacy policy, EasyWeb s.r.o. uses the personal data that the user provides or that is generated when using Flirtfox without creating a user profile and without separate consent solely for the purpose of carrying out the user relationship and out of the legitimate interest of EasyWeb s.r.o.

When installing the Flirtfox app without creating a user profile, EasyWeb s.r.o. collects the following data transmitted by the user's terminal device:

Such data is required for the installation of the Flirtfox app as such or is used for statistical purposes, to optimize Flirtfox. The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Flirtfox platform. For this purpose, we store the collected data in complete form for up to 90 days.

Location data is collected, processed and used to enable the user to use the so-called Location Based Service, which offers suggestions tailored to the respective location from the moment of registration. For more details on location data, please also see paragraph 3.1.3.

Further information on the use of cookies and other services can be found under s paragraph 5.

3. How is my data collected, processed and used after creating a user profile and when using the Flirtfox app?

EasyWeb s.r.o. uses the personal data that the user provides or that is collected when using Flirtfox after a user profile has been created without separate consent solely for the purpose of carrying out the user relationship and out of the legitimate interest of Flirtfox in accordance with this privacy policy. To use Flirtfox to its full extent, the user must create a user profile. For this purpose, the user must provide additional personal data that EasyWeb s.r.o. uses to provide the respective service.

3.1. Data that you have provided us with

3.1.1. Mandatory information

When creating the user profile and registration, the following information must be provided. Note: When registering with Facebook Login, Google Login, Apple Login, the required data is partially transferred automatically.

The data provided will be collected, processed and used for the purpose of using Flirtfox. Among other things, the information is used for addressing, authentication, age verification, personalization of the profile, display of other suitable user profiles and in pseudonymous form for advertising purposes (see also paragraph 4).

We delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR.

3.1.2. Voluntary information

The user can make a variety of voluntary entries in his user profile and set search filters. This serves in particular the function of Flirtfox to select recommendations for other user profiles according to different criteria for the user and to display them within Flirtfox. Additional information increases the probability of coming into contact with suitable user profiles. This information is voluntary for the user and can be viewed, entered, changed or deleted in the profile under Details.

The data provided will be collected, processed and used by us for the purpose of using Flirtfox. This voluntary information is visible to other logged-in users within Flirtfox as "public", but can be deleted or changed by the user profile owner at any time under the settings within the user profile. Furthermore, this data can also be processed and used for advertising purposes (see details on advertising under paragraph 4).

We delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR.8

3.1.3 Location data

The range of services offered by Flirtfox also includes so-called location-based services, which present the user with special offers tailored to the respective location. This enables the user to be shown other users, in particular those who are in the vicinity. To provide these functions within the Flirtfox app, Flirtfox collects location data using GPS of the terminal device used, as well as location data from nearby radio access nodes.

Prior to the first collection of location data, the user must allow the collection of location data. Processing of the location data will then take place in accordance with this privacy policy. Once the collection of location data is active, the location will be regularly transferred to EasyWeb s.r.o. for processing and use if permission is granted.

The user can adjust this function in the settings of the operating system on his terminal device at any time, i.e. allow the collection of location data or revoke its use.

The location data is also processed by Flirtfox for advertising purposes, unless the user has objected to its use in the app settings. (see details on advertising under paragraph 4).

We store location data in unabridged form for up to 14 days and in abridged form for up to 90 days.

The legal basis for this processing of personal data is Art. 6 I lit. b) or f ) EU-GDPR.

3.2 Data we receive as a result of your use of the Flirtfox app

3.2.1 IP addresses and network data

The IP addresses and related network data (e.g. the country in which the IP is registered) of users are recorded for security and verification purposes. The purpose is to prevent misuse of the service.

The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Flirtfox platform.

To this end, we store the collected data in full for up to 90 days, after that until your profile is deleted. The legal basis for this processing of personal data is Art. 6 I f) EU-GDPR.

3.2.2 Device data

When using the app or the website, we receive information about the device used, such as the manufacturer, operating system, advertising ID.

The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Flirtfox platform.

To this end, we store the collected data in complete form for up to 90 days and delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I f) EU-GDPR.

3.2.3. Event data

By using the app, we receive information about your actions (a so-called event) in the app, for example when you click data, search for users, create a match or send messages.

The data provided will be stored, processed and used by us for the purpose of using Flirtfox. This serves in particular the function of Flirtfox to select recommendations for other user profiles according to different criteria for the user and display them within Flirtfox. This additional information increases the probability of coming into contact with suitable user profiles. This data is an important part of understanding which profiles are likely to be of interest to you and which profiles you want us to display.

This data is also stored, processed and used to prevent and combat fake profiles, illegal activities and spam and to ensure the integrity and stability of the Flirtfox platform.

We delete this data when you delete your user account.

The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR or Art. 6 I lit. f) EU-GDPR.

3.3 Payment details (In-App purchases)

We do not collect or process your personal information when you purchase or download Flirtfox through an App Store. Such data, especially data for electronic payment processing, is only collected and processed directly by the App Store concerned. When using the App Stores, please refer to their privacy policies:

If you have any questions regarding the processing of your personal data by the App Store concerned (e.g. How can I delete my data?), please contact the App Store where you downloaded or purchased an App directly.

4. How will my data be used by Flirtfox for advertising purposes?

We use data for advertising purposes in two ways:

  1. For self-promotion
  2. To display personalized advertising

4.1. How will Flirtfox use my data for self-promotion?

On our platform, we display self-advertising to our users and also inform them by e-mail, e.g. about one-off promotions, reduced package prices or similar offers. To be able to display suitable offers, we use information that is provided to us by the user (such as profile data) and information that we automatically receive as a result of using our platform.

At any time, the user can object to the use of the service for advertising purposes by deactivating personalized advertising in the app settings under Privacy, or in his device settings.

The data will only be passed on as described under paragraph 6.

The legal basis for this processing is the legitimate interest of Flirtfox according to Art. 6 I lit. f GDPR.

4.2. How will Flirtfox use my information to display personalized advertising?

4.2.1. Personalized advertising

EasyWeb s.r.o. has chosen a freemium model for Flirtfox, i.e. a basic version of Flirtfox can be used by any user without paying a fee. However, the user is shown advertising in the free version. The advertising displayed on Flirtfox includes its own advertising content (e.g. via Flirtfox' VIP membership).

4.2.2. Sharing of data with third parties

EasyWeb s.r.o. only shares data with third parties in exceptional cases when this is urgently necessary for the function of Flirtfox. Otherwise, no data will be shared with other third parties.

4.2.3. Legal basis for the use of data to display personalized advertising

EasyWeb s.r.o. bases the processing and disclosure of the above data on the fulfillment of the contract with the user, his or her consent and the legitimate interest of Flirtfox.

EasyWeb s.r.o. provides its service in the Freemium model, which means that parts of Flirtfox are free of charge. To enable users to use the Flirtfox platform free of charge, Flirtfox displays advertising and uses personal data for this purpose in accordance with the above-mentioned provisions.

A prerequisite for the transfer of the above data to the recipients is always that contractual, legal, technical and organizational measures are taken to ensure that the data is used exclusively in a manner that complies with data protection laws.

By using the app, the user agrees to the transfer of his data, which is necessary in exceptional cases, already in the free version.

EasyWeb s.r.o. has limited its selection of data to those data that, even if they become known, whether through breach of law or hacking attacks on EasyWeb s.r.o. partners, do not have a high level of sensitivity for individual users. For this reason, Flirtfox only passes on the data in a pseudonymized form, i.e. individual users can only be identified with a great deal of technical effort and by breaking the law.

Flirtfox only passes on data that the user has voluntarily made public in the Flirtfox app and that is therefore recognizable by the user as being of low sensitivity, and device and connection data that by its very nature is not sensitive.

5. Which cookies and other services are integrated?

5.1 Cookies

The Flirtfox app was developed technologically in a way that it does not require cookies and therefore does not store cookies.

5.2 Facebook-Connect

EasyWeb s.r.o. offers the user the possibility to sign up for Flirtfox with Facebook Connect. To register, the user is redirected to the Facebook page (operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA), where he/she logs in with his/her user data, if not already logged in. By clicking the user's name, the respective Facebook profile and the user profile at Flirtfox are then linked together. Through the link, EasyWeb s.r.o. automatically receives the user's data from Facebook in the form of the e-mail address and other data within the user's public Facebook profile. The public Facebook profile contains data that the user has made available to the public on Facebook. Typically, the public Facebook profile includes the following data: Name, profile picture, gender, language, country, age range, Facebook ID, friends, likes and relationship status.

From this data transferred from Facebook, EasyWeb s.r.o. uses the e-mail address, Facebook ID, profile picture, likes and birthday. This information is used for the user profile. Further information about Facebook Connect and privacy settings can be found in the Facebook Privacy Notice and Terms of Use at www.facebook.com/policy.php.

The legal basis for data processing is then the consent of the user according to Art. 6 I lit. a) GDPR.

5.3 Google Ads (formerly Google AdWords)

We use "Google Ads" (formerly Google AdWords), a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Ads enables us to draw attention to our attractive offers by means of advertising on external websites. This enables us to determine how successful individual advertising measures are. These advertising materials are delivered by Google via so-called "AdServers". We use so-called AdServer-Cookies for this purpose, through which certain parameters for measuring success, such as the display of the ads or clicks by users, can be measured. If you reach Flirtfox via a Google ad, Google Ads will store a cookie on your device. These cookies usually expire after 30 days. They are not intended to identify you personally. The following information is usually stored as analysis values for this cookie: Unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies enable Google to recognize your web browser. If a user visits certain pages of an ads client and the cookie stored on their computer has not expired, Google and the client can recognize that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each ad client. Cookies cannot be tracked through the websites of ad clients. We ourselves do not collect and process any personal data in the advertising measures mentioned above. We only receive statistical evaluations from Google. By means of these evaluations we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material, in particular we cannot identify the users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. To our knowledge, Google receives the information that you have called up the corresponding part of Flirtfox or clicked on an ad from us. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, there is a possibility that Google will find out and save your IP address.

We use Google Ads for marketing and optimization purposes, in particular to deliver ads that are relevant and interesting to you, to improve campaign performance reports and to achieve fair calculation of advertising costs. This is also our legitimate interest in the processing of the above data by the third party provider. You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in your web browser settings. Please note that in this case you may not be able to use all functions of Flirtfox to their full extent. You can also prevent the storage of cookies by setting your web browser to block cookies from the domain "www.googleadservices.com" (www.google.com/settings/ads). We would like to point out that this setting will be deleted if you delete your cookies. In addition, you can deactivate interest-based ads by clicking on the link http://optout.aboutads.info. Please note that this setting will also be deleted if you delete your cookies.

Third party information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Irland

Further information on the use of data by Google, on setting and objection possibilities as well as on data protection can be found on the following websites of Google:

6. How data is disclosed or passed on

EasyWeb s.r.o. does not pass on users' personal data to third parties unless the user has given his or her consent to do so, the transfer is required by law or is permitted by law.

6.1 General information on the disclosure of personal data

User data and other data

EasyWeb s.r.o. may pass on customer data to the following third parties for the purpose of executing the contract:

Other disclosures

EasyWeb s.r.o. may share or disclose customer information as follows:

6.2 Categories of data recipients

EasyWeb s.r.o. will only disclose your personal data to third parties if this is necessary to fulfill our own business purposes (i.e. in particular to provide the services we owe you), if you have given your consent to do so, if it is in our legitimate interest to do so, or if we are required to do so by law or by court or governmental order.

We cooperate with external service providers within the scope of data processing. This is usually done on the basis of so-called contract processing; in which we remain responsible for data processing. We check each of these service providers in advance for the measures they have taken for data protection and data security and thus ensure that the contractual regulations for the protection of personal data provided for by law are observed.

The following categories of recipients currently receive personal information from us:

Depending on the nature of the services provided, EasyWeb s.r.o. may also use affiliates as data processors to provide some or all of the services offered to the customer.

6.3 Third Countries

Data transmissions to third countries take place, but only in compliance with the legal requirements for admissibility. Data transmissions to the following countries are carried out in compliance with the respective legal admissibility requirements:

The Privacy Shield Agreement, the Adequacy Decision and the EU standard contractual clauses can be viewed on the website of the EU Commission (ec.europa.eu/info/law/law-topic/data-protection_en).

7. How is data processed and used to prevent and combat fake profiles, illegal activities and spam, and to ensure the integrity and stability of the Flirtfox app?

To combat fake profiles, illegal activities (fraud, extortion, prostitution, etc.), SPAM (third-party advertising) and to ensure the integrity and stability of the Flirtfox platform, personal data is used as follows:

Legal basis

Flirtfox supports the aforementioned data processing on the basis of art. 6 I lit. f GDPR. Flirtfox has a legitimate interest in keeping its platform stable and free of SPAM, legal infringements and fake profiles.

8. How does the data deletion and backup process work?

When the user profile is deleted (note: not by deleting the Flirtfox App!) or when we are notified accordingly, all collected data of the user is deleted or made anonymous. In addition, the user can at any time delete individual data in the profile himself or request us to do so via a corresponding notification.

Excluded from the deletion are data that must be kept due to legal regulations, for the execution of contracts or for the fulfillment of contracts with other users. Therefore, in the event of a deletion, Flirtfox does not delete the following data in particular immediately, but only after the expiry of a period of time:

When do we delete data that a user has shared with other users?

We delete data that is publicly accessible in user profiles, e.g. profile pictures, pictures in the stream and the profile data as soon as immediately according to the above standards.

We cannot simply delete information that a user has non-publicly shared with other users on the Flirtfox app without violating the rights of other users. Therefore, chat content is only deleted after both users have deleted each other.

When does the deletion take place?

Deletion from the production databases and thus from the Flirtfox interface is immediate; however, it can take up to 14 days before deletion from all server layers, cache memories and backup databases of Flirtfox occurs.

If deletion is not possible, the data will be made anonymous or blocked.

EasyWeb s.r.o. reserves the right to check profile files before deleting them and, if necessary, to save them if, based on certain facts, there is a suspicion that the user profiles are being used in a manner that violates the law or the contract. This serves to protect the users of the services of EasyWeb s.r.o.

Regardless of the deletion of data triggered by the user's profile deletion, Flirtfox automatically deletes historical data that is no longer required for the fulfillment of the contract (e.g. historical location data and IP data) at regular intervals.

EasyWeb s.r.o. creates so-called backups to secure the data stocks, which are overwritten after 14 days and thus permanently deleted. If these backups contain log files, they are also deleted. If a user profile is completely deleted, the log files are also deleted.

9. What data security measures are in place at Flirtfox?

EasyWeb s.r.o. takes user confidence and data protection extremely seriously. To prevent unauthorized access or disclosure of user data, to maintain data integrity, and to ensure the appropriate use of information, EasyWeb s.r.o. implements appropriate physical, technical, and administrative procedures to safeguard the information collected by EasyWeb s.r.o..

To ensure the best possible protection of the user's data, the Flirtfox app uses a secure SSL connection, i.e. the data is transmitted in encrypted form between the servers and the browser as well as between the servers and the app.

10. User rights: Consent and revocation, information, correction, deletion, transfer

10.1 Consent and revocation

By registering with Flirtfox, the user consents to the collection, storage and processing of his personal data in accordance with this privacy policy and the terms and conditions. The user must expressly declare this consent when creating the user profile. This consent, as well as the entire process of creating the user profile, is recorded by EasyWeb s.r.o.

The user can revoke his consent at any time with effect for the future. This can be done by deleting the user profile (not the Flirtfox App), at the specified locations in the Flirtfox App within the user profile or by sending us an e-mail or letter:

10.2 Information, correction, deletion, transmission

According to the applicable laws, the user has a right to free information about the personal data stored by him and, if applicable, a right to correction and/or deletion or transfer of this data.

For this purpose, the user can contact info@flirtfox.com by e-mail, for example.

The user also has the right to complain to a data protection supervisory authority about the processing of your personal data by the Flirtfox App.

11. Changes to the privacy policy

EasyWeb s.r.o. will update this privacy policy as necessary. The use of user data is subject to the current version, which can be found at flirtfox.com/privacy. In the event of a change to this statement regarding a material area (e.g. change of authorizations, new functions, a new contact person, etc.), the user will be notified by e-mail to the e-mail address linked to the user profile. If the user continues to access and use Flirtfox after these changes take effect, the user agrees to be legally bound by the revised Privacy Policy.

12. Contact person for data protection and data protection officer

In the event of questions regarding the collection, processing or use of personal data, the disclosure, correction, blocking or deletion of data as well as the revocation of consents granted, the user should - if applicable - delete his user profile (not the Flirtfox App) or change it at the specified points in the Flirtfox App within the user profile or contact us by e-mail or letter: