Privacy Policy

Fliff Inc. (“Fliff” or “we”, “our” or “us”) operates the Fliff platform, which includes the Fliff app and website, and all related social media pages (the foregoing, and all content, features, and materials thereon, shall hereinafter be collectively referred to as the “Platform”).

We believe that the privacy and security of your information and data (“Information”) is very important. This Privacy Policy (“Policy”) explains the types of Information we collect from users of the Platform, how that Information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully.

Any updates or modifications to this Policy will be posted in our mobile app and website. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy. This Policy is effective as of March 1, 2024.


Types of Information:

We may collect the following types of Information through our Platform:

  1. “Personal Data” such as your name, e-mail address, physical address, phone number, specific (e.g., street level) geolocation data and other information that can be used to directly identify you;
  2. “Device Information” which is information relating to the device you are using when you access our Platform, such as your device’s IP address, your device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.
  3. “Usage Data” which is data related to your use of the Platform such as the pages you visit, your actions within the Platform, the type of content you have accessed, seen, forwarded and/or clicked on, WiFi connections, general geolocation information, date and time stamps, log files, and diagnostic, crash, and performance logs and reports.
  4. “Biometric Data,” which is data comprised of facial photos, for the purpose of creating avatars (“Avatar(s)”) within our Platform. This data may be collected directly from users or generated through their and their device’s interactions with the Platform. Biometric Data may be processed to create personalized Avatars that enhance the user experience within the Platform. These Avatars may be customizable and used for various in-app activities and interactions. There is no requirement within the Platform to grant us the use of your Biometric Data, as all Platform Avatars are customizable and can be self-created without the use of such Biometric Data. 

As described in more detail below, we collect Personal Data and Biometric Data only when you provide it to us but may collect other types of Information whenever you use the Platform through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below). Personal Data and Biometric Data shall hereinafter be referred to collectively as the “Submitted Data.”


In order to access the contests available on our Platform, you are required to register an account and this process will require you to give us personal data (the “Personal Data”).

We use the Personal Data that we collect to provide you with the applicable services, features or functionality associated with your submission and also to respond to your requests, communicate with you regarding the Platform, send you promotional e-mails, guard against potential fraud, and comply with laws and regulations. When you submit Personal Data through the Platform, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving your consent to the collection, use and disclosure of your Personal Data as set forth in this Privacy Policy.


Biometric Data may be processed to create personalized Avatars that enhance the user experience within the Platform. These Avatars may be customizable and used for various in-Platform activities and interactions. Specifically, we may collect photographs and scans of facial features and expressions. This data is used solely for customizing your user experience within the Platform and is not used for any other purpose such as advertising or marketing to third parties. There is no requirement within the Platform to grant us the use of your Biometric Data, as all Platform Avatars are customizable and can be self-created without the use of such Biometric Data.  The legal basis for utilizing your Biometric Data is your prior consent, prior to utilizing and/or processing such data. 

We do not store or retain any Biometric Data, including Face Data. We may integrate third-party service providers within our Platform to assist with the processing of such Biometric Data for purposes of creating your Platform Avatar. These providers are contractually obligated to adhere to strict data protection standards and are prohibited from storing or retaining the data or using the data for any purpose other than the provision of services to us.


Whether or not you submit Personal Data or Biometric Data, any time you visit the Platform, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and also in aggregate form for internal business purposes, such as optimizing the Platform, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.


If you choose to connect to our Platform through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”) or others, we may collect Personal Data from your profile on such Social Network, such as your name, username, and e-mail address or other data, and we will use that Personal Data for the purposes set forth herein. In addition, our Platform may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.


In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes.

We may share your Information in the following instances:

  • (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; 
  • (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements; 
  • (iii) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or
  • (iv) We may integrate third-party service providers within our Platform to assist with the processing of Biometric Data for purposes of creating your Platform avatar. These providers are contractually obligated to adhere to strict data protection standards and are prohibited from using the data for any purpose other than the provision of services to us.


Our Platform includes a Chat Feature (as that term is defined in the Terms of Use) that allows users to communicate with each other in real-time. Any messages, content, or information you share through the Chat Feature will be processed and stored by us and our service providers to provide the chat functionality and maintain appropriate records.

Any messages, content, data, or other materials ("Chat Materials") that you upload, submit, or send through the chat feature will be owned exclusively by you, the user. However, by uploading, submitting or sending Chat Materials, you grant us a worldwide, non-exclusive, royalty-free, sub-licensable, and transferable license to host, store, use, display, reproduce, modify, adapt, edit, publish and distribute those Chat Materials solely for the purposes of operating, providing, and improving the chat feature and our services.

You represent and warrant that you own or have the necessary rights and permissions to use and authorize us to use any third-party Chat Materials as described in these terms. You will be solely responsible for any and all liability that may result from the Chat Materials that you submit or send. You acknowledge that sharing images, files or other content without the appropriate rights or licenses may violate third-party rights. You agree that we have no responsibility or liability for any claims relating to Chat Materials that you provide.

The chat feature must not be used to share, upload, or send any images, files or other content in a manner that infringes any copyrights, trademarks, rights of publicity, privacy rights, confidentiality obligations or other third-party intellectual property or proprietary rights. Doing so may result in termination or suspension of your access to the Chat Feature.

We reserve the right to remove or disable access to any Chat Materials, in whole or in part, that we believe violates these terms or applicable laws.

We may collect and store the following data related to your use of the chat feature:

  • Chat messages and attachments you send or receive;
  • Date, time, and metadata associated with your chat messages;
  • User identifiers and profile information of chat participants.

Chat data and Chat Materials will be retained in accordance with our data retention policies and legal obligations. We may access, review, and disclose chat data as necessary to comply with legal requirements, enforce our terms of service, maintain site integrity and safety, or for other lawful purposes. 

Please note that Chat Materials are not encrypted end-to-end, and system administrators and service providers involved in delivering the chat service may have the ability to access chat content as required to operate and troubleshoot the systems.

You should avoid sharing sensitive or confidential information through the Chat Feature that you do not want to be accessed or disclosed in this manner.


We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Platform, customizing the content offered to you on the Platform and delivering relevant advertising to you. Such technologies include:

  1. Cookies. Cookies are text files placed in your computer’s browser to store your preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the Platform and the content, offerings, or advertisements you see on the Platform. For example, we may use cookies to personalize your experience on the Platform (e.g., to recognize you by name when you return to the Platform), save your password in password-protected areas, and facilitate subscriptions or orders on the Platform. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, not accepting cookies may make certain features of the Platform unavailable to you.
  2. Web Beacons. We may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
  3. Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits (“SDKs”) that are incorporated into the Platform to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about your device or use of the Platform. A mobile SDK may act as the mobile version of a web beacon (see “Web Beacons” above) and we may use this technology to deliver or help our advertising partners deliver certain advertising through the Platform based on information associated with your mobile device.

By visiting the Platform you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Platform through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.


We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Platform or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. For purposes of clarity, Personal Data does not include any Biometric Data captured within the Platform for purposes of generating a user’s avatar. We do not retain Biometric Data. Once the Biometric Data is no longer needed, it will be securely deleted.


It is entirely your choice whether or not you provide the Submitted Data to us. We take reasonable precautions to protect our customers’ Submitted Data against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Submitted Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner. If you believe your Submitted Data is being improperly used by us or any third party, please immediately notify us via email at


The Platform is intended for and targeted to adults. We do not permit anyone under the age of 18 to use the Platform nor do we knowingly collect or solicit Personal Data directly from anyone under the age of 18. If you are under 18, please do not send any Personal Data about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Data, please contact us at


We engage certain third-party service providers to serve advertisements on our behalf across the Internet and to provide analytics services. We may also participate in affiliate advertising and allow affiliate links to be encoded on some of our pages. This means that we may earn a commission when you click on or make purchases via affiliate links.

Our advertisers or ad networks that serve advertisements may utilize Cookies or other similar technologies (including within the ads) to collect anonymous information from you such as your device identifiers, advertising IDs, and IP address, web browser, actions you take relating to the ads, any links you click on, and conversion information. This information may be used by us, our service providers and their clients in aggregated, anonymous form to, among other things, analyze and track aggregated data, determine the popularity of certain content or products, measure the effectiveness of ad campaigns, determine the proper amount of repeat views of a given ad, and deliver advertising and content targeted to your interests on our Platform and outside of our Platform on other websites (also known as “interest-based advertising”). These service providers are prohibited from collecting any Personal Data from you and we do not share any of your Personal Data with them.


As described above, we may use the Personal Data we collect from you to send you newsletters, push notifications, general communications and promotional e-mails, including promotional communications about our Platform and our or our partners’ products or services. If you do not want to receive such communications, you can opt out (as applicable) by using the unsubscribe link at the bottom of our communications, unchecking the applicable box to opt out when prompted, or by simply not opting in when prompted. You may also at any time opt out of receiving communications from us by sending an e-mail to with the subject line “Opt Out.

Please note that even if you unsubscribe from our communications, we may still need to contact you with important information related to your account and your purchases. For example, even if you have unsubscribed from our promotional emails, we will still send you emails to alert you to changes to our Terms of Use or Privacy Policy.


You can opt out of the collection and use of certain information, which we collect about you by automated means, by changing the settings in the device you use to access the Platform. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Platform.

When you access the Platform through a mobile device, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience and the content you receive. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time thereafter by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application, which will also cause you to lose the applicable feature for which such location data was collected.


We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such a policy will be re-posted in the “Privacy” section of our Platform with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy.


You represent and warrant that any Personal Data you provide us is true and correct and relates to you and not to any other person.

If you use the Platform, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.


If you have questions or comments about this Policy, please contact us at with “Privacy” in the subject line of your email.

These Terms of Use were last updated on March 1, 2024.