Privacy

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Welcome to the privacy policy of FLY. Please take the time to read it.

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We are aware of the trust you place in us by sharing your information with us and we intend to always maintain this trust. This starts with ensuring that you understand what information we collect, why we collect it, how it is used, and the choices available to you regarding that information. This policy describes our data privacy practices in plain language, keeping legal and technical jargon to a minimum.

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This privacy policy applies from 07/07/2023.

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1. ABOUT US

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The company responsible for your data (“Data Controller”) under this privacy policy is:

‍Wingmate

66 Av. des Champs-Élysées

75008 Paris, France

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2. WHERE THIS PRIVACY POLICY APPLIES

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This privacy policy applies to the websites, applications, events and other services that we operate under the FLY brand. For simplicity, we refer to all such services as the “Services” in this Privacy Policy. In order to make this very clear, we have added links to this privacy policy on all services to which it applies.

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Some services may have their own privacy policy. If a service has its own privacy policy, then that privacy policy — not this privacy policy — applies.

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3. INFORMATION WE COLLECT

It goes without saying that we cannot help you meet people without having certain information about you, such as basic information about your profile and the type of people you wish to meet. We also collect information about how you use our services, such as access logs, as well as information from third parties, such as when you access our services through your social media account or when you download information from your social media account to complete your profile. We give you p more details below.

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Information you provide to us

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When you use our services, you choose to provide us with certain information. For example :

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By creating an account, you provide us with at least your login details or your telephone number, as well as certain basic information necessary for the operation of the service, such as your gender and your date of birth.

By completing your profile, you may share additional information with us, such as details about your personality, lifestyle, interests and other details about yourself, as well as content such as photos and videos. To add certain content, such as photos or videos, you can give us access to your camera or photo gallery.

By subscribing to a paid service or making a purchase directly on our platforms (rather than through a platform such as iOS or Android), you are providing us or our payment service provider with information, such as your debit or credit card number or other financial information.

When you participate in surveys, focus groups or market research, you give us your opinion on our products and services, your answers to our questions and your testimonials.

By choosing to participate in our promotions, events or contests, we collect the information you use to register or participate.

If you contact our customer service, we collect the information you provide to us as part of that interaction.

If you share information about other people with us (for example, if you use a friend's contact information for a certain feature), we process this information on your behalf in order to respond to your request.

Of course, to ensure the proper functioning of the service, we also process your conversations with other users as well as the content you post.

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Information we receive from third parties

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In addition to information you may provide to us directly, we receive information about you from third parties, including:

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The users

Users may provide information about you when they use our services, such as when they interact with you or make a report about you.

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Social networks

You may decide to share information with us via your social network account, for example if you decide to create or log in to your FLY account via your social network or another account (for example, Facebook, Google or Apple ) or to upload information such as photos from one of your social media accounts (e.g., Facebook, Instagram, etc.) to our services.

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Affiliates

FLY is an independent company and has no affiliate.

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Other partners

We may receive information about you from our partners, including when FLY accounts may be created through a partner's service (in which case they pass registration information to us) or when our advertisements are published on a partner's service (in which case they may transmit information on the success of a campaign). Where permitted by law, we may also receive information from third parties about individuals suspected or convicted of malicious acts or offenses as part of our efforts to keep our users safe.

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Information generated when you use our services

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When you use our services, technical data is generated about the features you have used, how you have used them and the devices you use to access our services. See below for more details:

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Usage data

The use of our services generates data about your activity on them, for example how you use them (for example, when you logged in, the functions you used, the actions taken, the information that were presented to you, the address of the web pages that redirected you to us and the advertisements with which you interacted) or on your interactions with other users (for example, the users with whom you connect and interact, the moment of inte

reaction, the number of messages sent and received).

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Device Information

We collect information from and about the device(s) you use to access our services, including information about your equipment and software such as IP address, identifiers and type of device, application settings and features, application crashes, advertising IDs (which are randomly generated numbers that you can reset by going to your device settings), identifiers associated with cookies or other technologies that can uniquely identify a device or browser.

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Other information with your consent

If you give us permission, we may collect your precise geolocation (latitude and longitude). The collection of your geolocation can take place in the background, even when you are not using our services, if the authorization you have given us expressly allows this collection. If you do not agree that we collect your precise geolocation, we will not. Similarly, if you consent, we may collect photos and videos (for example, if you want to post a photo or video or use streaming features on our Services).

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4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow third parties to use cookies and other similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). You can consult our Cookies Policy for more information on why we use them and how you can better control their use.

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Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a "Do Not Track" feature that tells a website that a user does not want their activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser may prevent that website from collecting certain information about the browser user. Not all browsers have a DNT option and DNT signals are not standardized. For this reason, many companies, including FLY, do not currently respond to DNT signals.

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5. HOW WE USE YOUR INFORMATION

The main reason we use your information is to provide and improve our services. In addition, we use your information to ensure your security. Read on for more detailed explanations of the different purposes for which we use your information, as well as concrete examples.

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A. To manage your account and provide our services to you

Create and manage your account

Provide you with customer service and respond to your inquiries

Complete your transactions

Communicate with you about our services

B. To help you connect with other users

Recommend other users to meet

Show user profiles to each other

C. Administer sweepstakes, contests, discounts or other offers.

Carry out and measure the effectiveness of advertising campaigns on our services and marketing campaigns promoting FLY on and outside our services

Communicate with you about products or services that we believe may be of interest to you.

D. To improve our services and develop new ones

Manage focus groups, market research and surveys

Analyze interactions with customer service teams with the aim of improving the quality of our service

Understand how users generally use the Services in order to improve them (for example, we may decide to change the design or interface or even significantly modify a feature based on user reactions to this feature)

Develop new features and services (for example, we may decide to create a new feature based on the interests of our users if they request it).

E. To prevent, detect and combat fraud and any other illegal or unauthorized activities

Detect and address actual, suspected or alleged violations of our Terms of Use, including by reviewing reports and user interactions.

Better understand and take action to address violations of our Terms of Use.

Retain data relating to violations of our terms of use in order to prevent any recurrence.

Enforce or exercise our rights, such as our terms of use.

Inform users who send a report of the actions taken as a result of the latter.

F. To ensure legal compliance

Comply with legal requirements

Help law enforcement

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To process your information as described in this Privacy Policy, we rely on the following legal bases:

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To provide our service to you: The reason we process your information for purposes A and B above is to perform the contract you have entered into with us. For example, when you use our service to meet people, we use your information to manage your account and profile, make it visible to other users and recommend other users to you and provide you with our free and paid features.

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Legitimate interests: We process your information for purposes C, D and E above, based on our legitimate interest. For example, we analyze user behavior on our services in order to continually improve our offers, we suggest offers to you which we think you might be interested in and promote our own services, we process information to ensure the safety of our users and we process the data, if necessary, to enforce our rights, to help law enforcement and to enable us to defend ourselves in the event of legal action.

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Comply with applicable laws and regulations: We process your information under Purpose F above, where necessary, in order to comply with applicable laws and regulations and to demonstrate our compliance with applicable laws and regulations. For example, we retain traffic and transaction data to comply with our accounting, tax and other legal data retention obligations, and to be able to respond to valid law enforcement access requests. We also keep data proving the consents that users have given us and the decisions that they may have taken to refuse a given function or treatment.

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Consent: If you choose to provide us with information that may be considered "special" or "sensitive" in certain jurisdictions, such as your sexual orientation, you consent to our processing that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geolocation or to use your information for specific purposes. In some cases, you can withdraw your consent by changing your settings (for example regarding the collection of your precise geolocation) or by deleting your content (for example where you have entered information in your profile which may be considered " special” or “sensitive”). In any case, you can withdraw your consent at any time by contacting us at the address indicated at the end of this privacy policy.

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6. HOW WE SHARE YOUR INFORMATION

Since our goal is to help you meet new people, the main sharing of user information is, of course, with other users. We also share some of our users' information with service providers and partners who help us run the services, and, in some cases, with legal authorities. Read on for more details on how your information is shared with others.

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With other users

You share information with other users when you voluntarily disclose information on the service (including on your public profile). Be careful with your data and make sure the content you share is content that you are comfortable making visible.

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If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

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If someone makes a report about you (to report, for example, that you have violated our Terms of Service or our Community Rules), we reserve the right to communicate the actions we have taken following this report, the case

applicable.

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With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with a variety of tasks, including data hosting and maintenance, analytics, customer service, marketing, advertising, payment processing, and security operations. We also share information with partners who distribute and help us advertise our services. For example, we may share limited information about you with our advertising partners in hashed, non-human readable form.

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We follow a rigorous vetting process before engaging a service provider or working with a partner. Our service providers and partners are subject to strict confidentiality obligations.

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For corporate transactions

We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change in ownership or control.

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With law enforcement / when required by law

We may release your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government or police investigation, or other requirements legal; (ii) to assist in the prevention or detection of illegal activity (subject, in each case, to applicable law); or (iii) to protect the safety of any person.

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To exercise our legal rights

We may also share information: (i) if disclosure would mitigate our liability in any pending or potential legal action; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

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With your consent or at your request

We may ask for your consent to share your information with third parties. In such a case, we will clearly indicate why we want to share the information.

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In the above scenarios, we may use and share non-personal data (i.e. information that by itself does not identify you, such as device information , general demographic data, general behavioral data, geolocation in an anonymized form), as well as personal data in a hashed and non-human readable form. We may also share this information with other third parties (including advertisers) to develop and deliver targeted advertisements on our Services and on third party websites or applications, and for and to perform analytics. and reports on advertising that you see. We may combine this data with non-personal data or additional personal data in hashed, non-human readable form collected from other sources. You will find more information about our use of cookies and similar technologies in our Cookie Policy.

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7. CROSS-BORDER DATA TRANSFERS

The sharing of information described in Section 6 involves cross-border transfers of data to the United States of America and other jurisdictions which may have different data processing laws. Where we transfer personal information outside of the EEA, the United Kingdom, Switzerland or other countries whose data protection laws have been deemed adequate by the European Commission or other relevant government body, we use standard contractual clauses (standard contractual clauses are commitments between companies that transfer personal data, obliging them to protect the confidentiality and security of your data) or any other appropriate transfer mechanism. We are currently reviewing our transfers to our service providers and the associated legal basis following the recent judgment of the Court of Justice of the European Union on transfers of personal data to the United States.

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8. YOUR RIGHTS

We want you to have control over your information, which is why we remind you of the following options and tools that are available to you:

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Tools for accessing and updating the service. Account tools and settings may allow you to access, correct, or delete the information you have provided to us that is associated with your account directly within the Service. If you have any questions about these tools and settings, please contact our customer service team for assistance.

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Device permissions. Mobile platforms may have permission systems for specific types of device data and notifications, such as phone contacts, photos, location services, push notifications and advertising IDs. You can modify your settings on your device to consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you object, certain features of the services may no longer be available.

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Uninstallation. You can stop all information collection by an app by uninstalling it using your device's standard uninstall process. Remember that uninstalling an app does NOT delete your account. To delete your account, please use the corresponding functionality on the service.

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Account deletion. You can delete your account using the corresponding functionality directly on the service.

We also want you to be aware of your data protection rights. Here are some key points to remember:

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Review of your information. Applicable privacy laws may give you the right to review the personal information we maintain about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or changes to these terms). You can exercise this right by submitting such a request here.

Updating your information. If you believe that the information we hold about you is inaccurate or that we no longer have the authority to use it and you wish to request its rectification, deletion, objection to or restriction of its processing, please contact us here.

For your protection and that of all our users, we may ask you to provide proof of your identity before we can respond to the above requests.

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Keep in mind that we may reject requests, including if we are unable to authenticate you, if the request is illegal or invalid, or if it may infringe trade secrets or intellectual property or privacy. or other rights of a third party. If you would like to receive information about another user, such as a copy of messages you received from them on our service, the other user will need to contact us to provide written consent before the information is shared. We may also ask them to provide proof of their identity before we can respond to the request.

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In addition, we may not be able to satisfy certain requests to oppose or restrict the processing of your personal data, in particular when these requests would no longer allow us to provide you with our service. For example, we cannot provide our service if we do not have your date of birth because we would not be able to know if you are over 18.

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In some countries, including the European Economic Area and the United Kingdom, you have the right to complain to the appropriate data protection authority if you have any concerns about how we process your personal information. You can find information about your competent data protection regulator in the European Economic Area here, and in the UK here. The data protection authority with which you can lodge a complaint may be that of your habitual residence, your place of work or the place where the alleged infringement took place.

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9. DURATION OF RETENTION OF YOUR INFORMATION

We retain your personal data for as long as necessary for our legitimate business purposes and as permitted by applicable law (as set out in Section 5) and in compliance with applicable laws. If you decide to no longer use our services, you can close your account and your profile will no longer be visible to other users. Please note that we will automatically close your account if you are inactive for a period of two years. After your account is closed, we will delete your personal information, as set out below:

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To ensure the safety and security of our users, we implement a safety retention window of three months after account closure. During this period, we retain your information in the event that it is necessary to investigate unlawful or harmful behavior. Retention of information during this security retention window is based on our legitimate interest as well as that of potential third party victims.

After the safety retention window has elapsed, we delete your data and retain only limited information for specific purposes, as set out below:

We retain limited data to comply with our legal data retention obligations: in particular, we retain transaction data for 10 years to comply with legal tax and accounting requirements. We may also need to retain “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents users give us for five years to demonstrate our compliance with applicable laws.

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We retain limited information based on our legitimate interest: we retain customer service records and associated supporting information and inaccurate location of downloads/purchases for five years to support our customer service decisions, enforce our rights and allow us to defend ourselves in the event of a claim, profile data for one year in anticipation of a potential dispute, for the establishment, exercise or defense of legal rights. Finally, we keep the data necessary to prevent users who have been banned or people who are found to be under the age of 18 from creating a new account, to ensure security and protect the vital interests of our users.

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Finally, we retain information on the basis of our legitimate interest when there is a potential or proven problem, complaint or litigation requiring the retention of the information (including if we receive a subpoena or a valid legal request asking us to retain the information). data – in which case we would need to retain the data to comply with our legal obligations – or if the data is otherwise necessary in connection with legal proceedings).

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10. PROTECTION OF CHILDREN'S PRIVACY

Our services are reserved for adults. We do not allow anyone under the age of 18 on our platform. If you suspect that a user is underage, please use the reporting mechanism available to you on the service.

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11. CANDIDATES, CONTRACTUALS AND PROVIDER REPRESENTATIVES

We also process the personal data of our candidates, our contractors and the representatives of our service providers, as part of our recruitment and talent management operations or our management of the services provided by our contractors and service providers. If you are a candidate for one of our positions, a contractor or a representative of FLY service providers, certain clauses of this privacy policy apply to our processing of your personal information, including the sections of this privacy policy that deal with the entity responsible for processing your personal data, transfers of personal data, the rights you may have under applicable law, how to contact us.

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If you are a candidate for one of our positions, the personal data about you that we process may vary depending on the position you are applying for, but generally includes the information you provide to us as part of your application, as well as your professional qualifications, your background and references that recruiters or other third parties share with us. We use this information as part of the recruitment process, which may lead to an employment contract. For contractors and supplier representatives, we may process identifying information and business information as necessary to manage our relationship with you and your employer, to perform the contract for services, and to establish, exercise or defend against possible legal claims. We may share your personal data with service providers who assist us in recruitment and technical data processing operations. We keep your personal data for as long as necessary for these purposes.

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12. CHANGES TO PRIVACY POLICY

As we are always looking for new and innovative ways to help you meet new people and strive to ensure that explanations of our data practices remain up to date, this policy is subject to change. sometimes. We will notify you prior to any material changes becoming effective so that you have time to become aware of the changes

13. HOW TO CONTACT US

If you have any questions regarding this privacy policy, you can contact us on the email address contact@fly-dating.com