Flatters (“Company”, “we”, “us” or “our”) provides you, our customer and user (“you”), with the Flatters app (“App”) enabling you to have your photos edited by the Flatters’ team of editors (“Services”). This privacy policy (“Privacy Policy”) discloses our processing practices and specifically how or why we collect, share and use our users' data and governs your use of the App, Services or our website available at: https://flatters.com.

This Privacy Policy is an integrated part of our Terms of Service, definitions herein shall have the meaning assigned to them in the Terms.

We may update the Privacy Policy from time to time, the last and updated version is reflected in the "Last Updated" heading above. In the event of a material change we will make best efforts to provide a written notification through your account, the App or our website.

DATA COLLECTED AND PURPOSE OF USE

Depending on your interaction with us, we may collect two types of data from you:

• Non-identifiable information, which is made available or processed through your use of the App and Service, to clarify, this information does not disclose your identity (“Non-Personal Data”).
• Individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”), this information also includes online identifiers such as machine ID, Advertising ID and IP addresses (“Online Identifiers”).
• If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.

When you access the website, App or use the Service, we will collect Non-Personal Data, such as technical, aggregated data, including the type of device; time and date you access the App and use the Services, language preference, type of device, etc. We use this data solely to provide and enhance our Services and to enable operation of the App.
If you voluntarily contact us, you may be required to provide us with certain information such as your name and email address. We will use this data solely to provide you with the support you have requested or response to your inquiry.
To register and create an account you will need to create an account by providing us with your name, email address, password and profile picture. You are solely responsible to keep your password secure and confidential. We will use this information solely to provide you with the Service you have requested and open an account on our platform. Additionally, an email will be sent out once your photo submissions are ready to download.
When you access our website or App, we do not collect Online Identifiers.
We provide a 7-day free trial, following which you will need to subscribe to continue using our Services. Any and all payments are made through the App Store and are subject to their terms and privacy policy.
Please see the Apple Privacy Policy for more information: https://www.apple.com/legal/privacy/en-ww/
When you edit your photos, you understand our editing team and we, will be exposed to such content. Thus, please make sure you do not share any personal or sensitive images or photos with us. We will solely use the information, provided voluntarily by you, for the purpose of editing the content and providing you with the Services.

HOW WE COLLECT THE DATA
We collect the above data from you, in the following ways:

• Automatically, when you interact with our App and website; or
• When you voluntarily choose to provide us with information, i.e. when you contact us, register or upload any photos. Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Data and offer you the choice to opt-out.

SHARING DATA WITH THIRD PARTIES
We will not share your Personal Data with third parties, except in the following events:

1. User’s explicit consent - we may disclose your Personal Data to third parties upon your explicit consent. Please note that once we share your information with third party, that information becomes subject to the other third party’s privacy practices.
2. Policy and Law enforcement - we may disclose or share your Personal Data, solely to the extent needed to enforce our policies and to exercise our legal rights.
3. Third party rights - we may share your Personal Data in order to prevent breach of third party rights.
4. Affiliate company and corporate transaction- we may disclose or share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under common control ("Affiliated Companies") solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of a corporate transaction.
5. Service Providers - we may disclose Personal Data to our service providers to perform requested services on our behalf, e.g. photo editors, in-app payment processors, etc.

DATA RETENTION
We retain the data we have collected for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed below.

USERS’ RIGHTS & CONTROLS
Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Data. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Data they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Data to another party.
We provide you with the ability to exercise certain choices and controls in connection with our processing of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please download our applicable form available at: [download form] and send it to our privacy email at: privacy@flatters.com.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

SECURITY OF THE DATA
We take great care in implementing and maintaining the security of the app or Service and your Personal Data. We employ industry standard procedures and policies and implemented technical and administrative security measures to ensure the safety of our users’ Personal Data and prevent unauthorized access or use of any such information. For more information regarding our security measures, please click here: www.flatters.com/security If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted to abuse our app or Service or acted in an inappropriate manner, please contact us directly at: privacy@flatters.com.

CHILDREN PRIVACY AND DATA
The Services are not intended for children, accordingly, we do not use the Service to knowingly solicit data from children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area ("EEA") individuals). We request that children do not provide Personal Data through our Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at privacy@flatters.com and we take reasonable steps to ensure that such information is deleted from our files.

TRANSFER OF DATA
If you visit our App or use our Services, please note that any information you provide to us through your use of our app or Service may be transferred to and processed in countries other than the country from which you accessed our App. If you are a resident of the EEA, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction, where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

FURTHER QUESTIONS?
If you have any questions about this Privacy Policy, please contact at: privacy@flatters.com or by contacting us at:

Flatters
One Welches, First Floor
Welches, St. Thomas
Barbados