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Privacy Policy

Version 1.1 — effective May 28, 2025

1. General provisions and terms

Flect is an application developed for mobile devices that provides Users with psychological advice and recommendations on the ChatGPT platform in conversational mode in a dialogue format with artificial intelligence. When using the Application, the User has the opportunity to take tests to determine his mental state, conduct dialogues with artificial intelligence, follow recommendations to increase positivity and find ways to achieve life goals.

Flect is hereinafter referred to as “Flect” or “App” or “Flect App”.

User — is an individual who has reached the age of majority established by the laws of a particular state separately, using the Flect App in the United States, who has read this Privacy Policy and the Terms of Service and has agreed to accept the terms of such documents.

Below in the text, we use the address “you” to Users.

The use of the Flect is possible for adult US citizens.

Flect App Inc. — is the legal entity registered at 561 Applewood Court, Howell Township, NJ 07731, which owns the rights to the Flect App and is the data controller (as defined by the privacy laws of individual states in America).

Data controller — is a company that, alone or jointly with others, determines the purpose and means of processing personal data must provide consumers with information on how to collect, process and protect their financial data.

ChatGPT — is a generative AI chatbot developed by OpenAI that is conversational and supports queries in natural languages. ChatGPT is capable of answering questions and generating texts in different languages related to various subject areas. An important feature is the ability to generate programs on demand in various programming languages.

Personal data — information relating directly or indirectly to a specific individual (User), which may be provided to other persons. This Privacy Policy describes our practices with respect to Personal Data that we collect about User (from or about you) when you use our Flect App and services it provide.

Services — a set of services and opportunities provided to the User when using the Flect App.

Confidentiality of personal data — is a mandatory requirement for the controller or other person who has access to personal data to not allow their distribution without the consent of the User or the presence of another legal basis.

Flect App Inc. acts as a data controller in relation to any Personal Data you provide to us and will only process and share your data in line with the requirements of the applicable data protection laws and on the terms set out in this Privacy Policy. The processing of Personal Data is adequate, relevant, and reasonably necessary in relation to the purposes for which such data is processed.

2. Consent

Consent is one lawful basis for processing. When we ask for your consent, we do not use pre-ticked boxes. For example, when you register your account in the Flect App, you will need to read and accept this Privacy Policy by ticking the «I agree» box provided. This is known as positive opt-in.

Please note, that you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to rely on the Flect. Upon receipt of your withdrawal of consent, your Account will be deleted.

The practices described in this Privacy Policy are subject to applicable laws in the places in which operate Flect App Inc. This means that we only engage in the practices described in this Policy in a particular country or region if permitted under the laws of those places.

3. What personal data we collect about you and how

1) Personal data you provide

Account information. When you create an account with Flect, we will collect information about you:

  • First name;
  • Contact phone number;
  • Electronic mail (e-mail) address;
  • Date of birth;
  • User’s photo;
  • Other data you share with Flect through application tools (in AI-dialogue, sessions with AI, when creating logs).

You can choose which email address you register for your Account. However, please be aware that the use of third party email, including corporate email, is prohibited.

User content. We collect Personal Data that you provide in the input to our Services, including your hints, answers, texts, test results and other content you upload, such as images, and audio, depending on the features you use.

Communication information. If you communicate with us, such as via email or our pages on social media sites, we may collect Personal Data like your name, contact information, and the contents of the messages you send.

Other information you provide. We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with access to your calendar, voice, children’s information, business, career, job and other data that may be obtained about you by artificial intelligence, including when logging into the Flect by scanning your face (Face ID).

2) Personal data we receive from your use of the Flect

When you visit, use, or interact with the Flect, we receive the following information about your visit and use the App:

Log data. We collect information that your browser or device automatically sends when you use Flect. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request and other Technical Information.

Usage data. We collect information about the features you use and the actions you take on the Flect App, as well as your time zone, connection dates and times.

Device information. We may collect information about the device you use to access the Flect App, such as the name of the device, operating system, device identifiers, and browser you are using. The information collected may depend on the type of device you use and its settings.

Cookies and similar technologies. We use cookies and similar technologies to operate and administer the Flect App.

When using Flect, you may be exposed to the following information:

  • racial or ethnic origin,
  • religious beliefs,
  • mental or physical health condition or diagnosis (including pregnancy),
  • sex life or sexual orientation, including status as transgender or nonbinary,
  • national origin,
  • citizenship or immigration status,
  • genetic or biometric data,
  • transgender or nonbinary gender.

To the extent any of the above information is disclosed by you in the course of using Flect, you consent to our storing and processing such information about you and using it in our communications with you on the Flect App (dialogs, quizzes, recommendations, etc.).

Flect App Inc. warrants that the above information about you is protected in the manner and under the terms and conditions set forth in this Privacy Policy and applicable laws of the individual states.

Data that is generated as a result of your use of the Flect App:

  • The calculated indicator «Happy Lifestyle Index» — formed by the application to questions during onboarding, during your communications with an ChatGPT and when you are active or inactive in the Flect App.
  • Status, speed and content of your personal tasks: data is generated when you complete recommended tasks in the application;
  • Data about your physicals conditions — steps, pulse, sleep, stress, emotion state, etc.
  • The results of your tests in the application — for example, personality type, stress level and others.

3) Information we receive from other sources

We receive information from our trusted partners, such as security partners, to protect against fraud, abuse, and other security threats, and from marketing vendors.

We also collect information from other sources, like information that is publicly available on the internet, to develop the models that power the Flect App.

4. How we use your personal data

  • To provide Services in the Flect App, to analyze your activity in the Flect App, for example to respond to your questions for ChatGPT and in other similar cases;
  • To improve and develop our Services and conduct research, for example to develop new product features in the Flect App;
  • To communicate with you, including to send you information about our Services and events, for example about changes or improvements to the Flect App;
  • To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and the Flect App;
  • To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, Flect App Inc. or third parties.

5. When do we disclose personal data

1) For transmission to service providers if necessary to maintain the application Flect. To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, content delivery services, support and safety monitoring services, email communication software, web analytics services, payment and transaction processors, and other information technology providers. These parties will access, process, or store Personal Data only in the course of performing their duties to us.

2) To use ChatGPT. When you use the Flect App, you are connected to ChatGPT and as such you are using an OpenAI product and must comply with OpenAI’s terms and conditions for using ChatGPT.

3) Flect App Inc. affiliates. We may disclose Personal Data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Flect App Inc. Our affiliates may use this Personal Data in a manner consistent with this Privacy Policy.

4) Upon sale or other transfer of our business. If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

5) At the request of government agencies. We may share your Personal Data, including information about your use of the Flect, with government authorities, industry peers, or other third parties in compliance with the law (i) if required to do so to comply with a legal obligation, or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, users, or the public, or (vi) to protect against legal liability.

6. Storage of personal data

We’ll retain your Personal Data for only as long as we need in order to provide our Services to you, or for other legitimate purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations.

How long we retain Personal Data will depend on a number of factors, such as:

  • Our purpose for processing the data (such as whether we need to retain the data to provide our Services);
  • The amount, nature, and sensitivity of the information;
  • The potential risk of harm from unauthorized use or disclosure;
  • Any legal requirements that we are subject to.

Flect App Inc. processes your Personal Data on servers located in the United States. The Data is stored in encrypted form.

7. Correction and deletion of personal data

In order to protect your Personal Data from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to correct, or delete Personal Data. If we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification.

If we have no compelling reason to continue processing your Personal Data, we may ask you to delete or move it.

You may delete their account in addition to deactivating it.

However, we may not always be able to comply with your complete deletion request of erasure for specific legal reasons.

To delete an account you can write a request for this by email support@getflect.app.

Please note that we are required to retain certain data by law and may retain certain data in accordance with statutory limitation periods.

Flect can decide to delete your Account in the cases specified in the Terms of Service.

Terms of Service are posted here: getflect.app/terms.

8. Guarantee

  1. US law, and in particular state privacy laws, sets forth a list of rights guaranteed to you with respect to your Personal Data. Flect App Inc. guarantees that when collecting, storing, processing, providing, deleting Personal Data (as well as other actions with Personal Data), applicable US laws are observed.
  2. We implement commercially reasonable technical, administrative, and organizational measures designed to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you provide to the Flect. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
  3. We do not knowingly collect Personal Information from people under the age of majority. If you have reason to believe that the minor has provided Personal Data to Flect through the Services, please email us at support@getflect.app. We will investigate your notification and, if appropriate, delete the Personal Data from our systems.
  4. We do not provide any actual medical or other health services on the Flect App. Nothing stated or posted on the application by us is intended to be, and must not be taken to be, the practice of medicine, dentistry, nursing or other healthcare professional services or the provision of medical care. Do not use the application or the Services for emergency medical needs. If you experience a medical emergency, immediately call your local emergency services.
  5. During any online consultation with a practitioner which is held on the Flect App, you may exchange special Personal Data with the Flect via ChatGPT including in relation to health (health history, symptoms, examinations and tests and the results thereof, diagnosis, treatment, and care plan), ethnicity, sexual orientation, sex life, religious beliefs or opinion or genetic data as relevant to the practitioner. This information is held and used by Flect App in accordance with our Privacy Policy, applicable laws and regulations.

9. Passwords and confidentiality

If you are provided with a password or any other piece of information as part of our security procedures for a registration-only section of Flect App, you are responsible for all activities that are carried out under them. We do not have the means to check the identities of people using the Flect App and we will not be liable where your password or username, email address or your mobile number is used by someone else. You agree to contact us immediately of any unauthorised use of your password or username of which you become aware. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if you have failed to comply with any of the provisions of these Privacy Policy or the Terms of Service.

10. Flect’s confidential information

During your use of the Services, Flect may share with you information that is confidential, sensitive or should be kept secret. For example, if we tell you about our plans, provide you with testing, give you process analysis, etc., these should always be considered confidential.

Also, if either of us provide any documents to the other that are labeled “confidential” (or something similar), or provide information (either in writing or verbal) that is of a type that a reasonable person should understand to be confidential, such information is to be treated as confidential information.

If you tell us information that: (a) we already know at the time you tell us; (b) was told to us by a third party who had the right to tell us; (c) is generally available to the public; or (d) was independently developed by us without using any of your confidential information, then that information will not be considered confidential. The same goes for information that we tell you that falls into any of these categories.

Lastly, we both agree that: (i) we will treat each other’s information with the same degree of care that we treat our own confidential information; (ii) will use each other’s confidential information only in connection with these Terms and the Services; (iii) only share the information with others who have a need to know and who have agreed in writing to treat it as confidential (as we’ve outlined in this section); and (iv) not share the information with any third party except as allowed in these Terms or through the Services. Of course, confidential information will always remain the property of its owner.

11. Changes to the privacy policy

We may occasionally update this Privacy Policy. If we make significant changes, we will notify you of the changes through the Flect App or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this Privacy Policy.

We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. We will also make prior versions of our Privacy Policy available for review.

12. Contacting us

Please contact us at support@getflect.app or 561 Applewood Court, Howell Township, NJ 07731 if you:

  • Have questions about this Privacy Policy;
  • Wish to make a complaint or have a concern about our handling of your personal information; or
  • Want to report a possible breach of privacy laws.

Postal address: 561 Applewood Court, Howell Township, NJ 07731.