FlowGPT Privacy Policy
Effective
date: October 24th, 2024
Last
updated date: October 23rd, 2024
This
privacy notice for FlowGPT, Cp. describes how and why
we might collect, store, use, and/or share ("process") your
information when you use our services ("Services"), such as when you:
·
Visit our website at FlowGPT.com, or any website of ours
that links to this privacy notice
·
Engage with us in other related ways, including any sales,
marketing, or events.
Reading
this privacy notice will help you understand your privacy rights and choices. IF
YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, PLEASE DO NOT USE OUR
SERVICES. IF YOU STILL HAVE ANY QUESTIONS OR CONCERNS, please contact us
at [email protected].
Personal
Data We Collect
Personal
information you disclose to us
We
collect information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products
and Services, when you participate in activities on the Services, or otherwise
when you contact us.
• Create an account and log in: When you register
and log in, we need to collect your email addresses, usernames and passwords;
• Collection and Use of User-Uploaded Content and Images: At FlowGPT, when you interact with various algorithm models to
submit content or upload images, we collect the data you provide. This is
essential for our service to function effectively. Your uploaded content and
images are stored on our servers for the same purpose. You retain the ability
to delete this information at any time, and we assure you that your data will
not be modified, sorted, or utilized beyond the intended function without your
consent. Please be aware that the information you upload may contain personal
or sensitive personal information. IF YOU CHOOSE TO UPLOAD CONTENT THAT
INCLUDES PERSONAL INFORMATION, IT IS YOUR RESPONSIBILITY TO ENSURE THAT YOU
HAVE OBTAINED THE NECESSARY PERMISSIONS AND CONSENTS FROM THE INDIVIDUALS
INVOLVED.
• Submission of Custom AI Models: When you decide to submit a
custom AI model with specific parameter adjustments on FlowGPT,
we require certain information to facilitate this process. This includes the
model's name, description, prompt words, and content, as well as a welcome
message that will be associated with your AI model.
• User Interaction Data Collection:: While using FlowGPT, you have the opportunity to comment on various AI
models. Please be aware that these comments are designed to be publicly
accessible, visible to the entire FlowGPT user
community. By submitting a comment, you are implicitly consenting to allow
other users to view, copy, download, or share your comment within the platform.
This consent is given in recognition of the collaborative and open nature of
the FlowGPT environment.
• When you browse FlowGPT services or
accessing content delivered by FlowGPT, we gather
essential information from your devices and applications, such as device name,
device identifier, device activation time, hardware model, operating system
version, application version, software identification code, device and
application settings (e.g., region, language, time zone, font size). This also
includes mobile network data like PLMN and cell identification codes for the
device's location, as well as IP addresses to enhance service functionality and
security.
• When you use FlowGPT services or
view content provided by FlowGPT, to ensure the
stable and secure operation of FlowGPT, we
automatically gather specific information and store it in logs, such as access
timestamps, access times, IP addresses, and event data (e.g., errors, crashes,
restarts, and upgrades).
• We offer value-added premium services, for which you need to
pay in the following way: through a third party (such as Apple Pay, Google Pay,
etc.) As a result of your payment, we may collect some financial information
(e.g., payment records or other payment-related data).
We
will not collect additional categories of Personal Data or use the Personal
Data we collected for materially different, unrelated or incompatible purposes
without providing you notice.
The
Permissions We Apply For Use
Image
Upload Authorization: When utilizing the image upload feature within FlowGPT, we request authorization to access your device's
photo album on your device. This permission is essential for a smooth and
efficient upload process, allowing you to share images with us effortlessly.
Notification
Permissions: To
ensure that you receive important messages, notifications, and reminders from FlowGPT, we seek to enable the necessary message
notification permissions on your device. By granting these permissions, you
allow us to keep you informed and up-to-date with
relevant updates and alerts, enhancing your interaction with our services.
Personal
Data We Obtain From Third Parties
Single-Sign
Ons – If you sign up to our website FlowGPT.com through Google, you authorize
us to collect your authentication information, such as your username and
encrypted access credentials, and other personal data available through the third party application account, including the following
personal data:
Google
– You can sign up and log in to FlowGPT using your
Google account. When you sign up using Google, Google will ask your permission
to share certain information from your Google account with FlowGPT.com. This
includes your Google email address and avatar (optional). This information is
collected by Google and is provided to us under the terms of Google’s privacy
policy. You can regulate the information that we receive from Google using your
Google activity controls. If you signed up using Google by mistake, you can
delete your account from the Account page within your Settings at any time, or
you can contact us by emailing us at [email protected]
Integration
of Third-Party Applications in FlowGPT's Services
It's
important to recognize that FlowGPT integrates with
various third-party applications, including but not limited to OpenAI and TTS
services. As you engage with these third-party features, ensure that you adhere
to their respective policies and guidelines. This includes following their privacy
policies, user agreements, and any other relevant authorization documents to
ensure a secure and compliant experience.
How
We Use Your Personal Data
We
use your personal data to:
·
To enhance the efficiency and precision of the message
delivery system, we will integrate third-party SDKs for push notification
services. These services may be active in both the user interface and
server-side components to ensure uninterrupted functionality. When enabled, the
system will collect and use your name to facilitate the timely dispatch of
messages and notifications via the integrated push SDK service.
·
Provide, Improve, and Develop the Platform - We process your
personal data primarily for the adequate performance of our website. We may
also process your personal data in light of our
legitimate interest in improving the Website and giving our users the best
experience. We do this to: Operate and
maintain your FlowGPT.com account, and to provide you with access to and use of
the Platform. Your email address and password are used to identify you when you
log into the Platform. Identify you as
the creator of the prompts that you upload, the comments that you post and/or
the other contributions that you make to the Website. Respond to you about any comment or enquiry
you have submitted.
·
Maintain a Safe and Secure Environment - We also process
your personal data in light of our legitimate interest in improving the
security of the Platform (including the security of your personal data) in
order to give our users the best experience.
How
We Share Your Personal Data
We
do not sell your personal data to external parties.
·
Through Your Profile – Any personal data that you choose to
disclose in your public profile on FlowGPT.com will be accessible by other
users of the website, who may view your profile information, view or and
comment on any of your public prompts.
·
Third Party Applications – If you choose to connect your FlowGPT account to other apps or social networks such as
Facebook and Twitter, you may be sharing certain personal data with these apps
or networks. Materials that you share with social media networks will appear on
your timeline (or similar functions) as well as in feeds that may be viewed by
the public or by certain followers, subject to the terms and conditions of such
social media networks.
·
Compliance with Laws – We may disclose your personal data to
courts, law enforcement agencies, and governmental authorities (i) to comply with our legal obligations, (ii) to comply
with legal process and to respond to claims asserted against FlowGPT.com, (iii)
to respond to verified requests relating to a criminal investigation or alleged
or suspected illegal activity or any other activity that may expose us, you, or
any other of our users to legal liability, (iv) to enforce and administer our
Terms of Use and other agreements with users, or (v) to protect the rights,
property or personal safety of FlowGPT.com, its employees, and members of the
public.
How
To Use Cookies and Related Technologies
FlowGPT utilizes local storage technologies, including cookies,
pixel labels, and web beacons, to enhance its websites, online services, email
communications, and advertisements. The data gathered through these mechanisms
is generally categorized as non-personal information. However, should regional
legislations classify IP addresses or similar identifiers as personal data, FlowGPT aligns with this perspective and treats such
identifiers with the same regard. It's also important to note that we may
combine this non-personal data with other personal information we possess. When
such data integration occurs, for the scope of this policy, we treat the
combined data as personal information, ensuring its collection, usage, and
protection in line with the guidelines outlined in our privacy policy.
●
Cookies
• Cookies are simple text files placed on
your computer or mobile device by a server. The server that created the cookie
is the only one that can access its content. Each cookie is tailored to your
specific web browser or app, and they typically include identifiers, site
names, and alphanumeric characters.
• FlowGPT employs
cookies to enhance your interaction experience, such as:
- Essential Cookies:
These facilitate login and
verification processes, allowing seamless navigation across our website without
repeated logins.
They also help in remembering
your preferences and settings, like language and font size, for a customized
browsing experience.
- Analytical Cookies:
These tools enable us to understand user engagement with our site by tracking
single or multiple visits, which assists in improving site functionality and
user satisfaction.
- Advertising
Cookies: Designed to deliver targeted advertising based on your online
activity, these cookies help us to present content and advertisements that are
most relevant to your interests.
You have the
ability to manage your cookie preferences, including deletion and
blocking options, through your web browser's settings. However, please be aware
that clearing cookies may necessitate reconfiguring user settings upon each
visit to FlowGPT's website, and disabling cookies
might impact the functionality of certain services.
●
Web Beacons/Pixel Labels
• Beyond cookies, FlowGPT and its
partners also employ web beacons and pixel labels. These are typically small
electronic images embedded within our website or emails, serving to recognize
when web pages or emails are viewed on your device. They also ensure that
emails are delivered in a readable format and inform us if they have been
opened.
• These technologies aid in analyzing service usage and tailoring
content and advertisements to better serve your needs. For instance, emails
from FlowGPT may include clickable links that lead to
specific content on our website. Tracking these interactions helps us to better
understand your preferences and enhance our customer service.
●
Additional Local Storage Technologies
We and our third-party
collaborators may also utilize other local storage solutions, such as local
shared objects (also known as Flash cookies) and HTML5 local storage. These
technologies, while similar to cookies, may differ in
the way they are used and stored on your device, and thus might not be
manageable through standard browser settings.
●
Do Not Track
• While many web browsers offer a "Do Not Track"
feature that sends a request to websites, there is currently no consensus among
major Internet standards organizations on how to respond to these requests.
• As of now, FlowGPT does not alter its
data processing practices in response to the "Do Not Track" setting
or similar features.
How
Do We Use Third-party SDKs
At
our service, we incorporate various third-party SDKs (Software Development
Kits) to enhance and optimize our offerings. Here's a breakdown of how we
utilize these tools:
• Firebase Push SDK: This SDK is
instrumental in delivering real-time message notifications to our users. By
leveraging the capabilities of Firebase, we ensure that you receive timely and
relevant updates and messages, thereby improving your engagement and experience
with our services.
• ClickStream
Analytics SDK: To continuously refine our product offerings and services,
we employ the ClickStream event tracking SDK. This
tool allows us to gather and analyze user behavior data, providing valuable
insights into how our users interact with our platform. This data is crucial
for identifying areas of improvement and for tailoring our services to better
meet your needs.
• Attribution SDK for Online Marketing:
Understanding the channels through which our users discover our services is key
to effective online marketing. By using an attribution SDK, we can accurately
track and analyze user acquisition across various marketing channels. This
enables us to make data-driven decisions and to optimize our marketing
strategies, ensuring that we reach the right audience with targeted and
relevant messages.
Our
use of these SDKs is in line with our commitment to providing a superior user
experience while maintaining the highest standards of privacy and data
security. We value your trust and ensure that any data collected through these
SDKs is handled responsibly and in accordance with our privacy policy.
Business
Transfers
All of your Personal Data that we collect may be transferred to a
third party if we undergo a merger, acquisition, bankruptcy or other
transaction in which that third party assumes control of our business (in whole
or in part). Should one of these events occur, we will make reasonable efforts
to notify you before your information becomes subject to different privacy and
security policies and practices.
Information
Security Retention
FlowGPT.com
maintains appropriate technical, administrative, and physical safeguards that
are designed to prevent unauthorized access, use or disclosure of personal data
we collect or store and to ensure a level of security appropriate to the risk
of varying likelihood and severity for the rights and freedoms of natural
persons that may be involved with our processing operations. We regularly
monitor our systems for possible vulnerabilities and attacks. However, it is
not possible to guarantee the security of personal data transmitted over the
Internet. You use the website and provide us with personal data at your own
discretion and risk.
We
seek to protect your Personal Data from unauthorized access, use and disclosure
using appropriate physical, technical, organizational and administrative
security measures based on the type of Personal Data and how we are processing
that data. You should also help protect your data by appropriately selecting
and protecting your password and/or other sign-on mechanism; limiting access to
your computer or device and browser; and signing off after you have finished
accessing your account. Although we work to protect the security of your
account and other data that we hold in our records, please be aware that no
method of transmitting data over the internet or storing data is completely
secure.
We
retain Personal Data about you for as long as you have an open account with us
or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is
necessary to comply with our legal obligations, resolve disputes or collect
fees owed, or is otherwise permitted or required by applicable law, rule or
regulation. We may further retain information in an anonymous or aggregated
form where that information would not identify you personally.
Personal
Data of Children
The
Children’s Online Privacy Protection Act ("“COPPA"”) requires that
online service providers obtain parental consent before they knowingly collect
personally identifiable information online from children who are under 13 years
of age. Our Services are not directed to children under 13. Also, we do not knowingly
collect or solicit personally identifiable information from a child under 16.
Specifically, we do not collect any personal information as defined by COPPA
from the FlowGPT mobile application when a user only
uses such application without registering an account with the FlowGPT Services, and we do not allow users who identify
themselves as under the age of 16 to register for an account with the FlowGPT Service. If you are a child under 16 years of age,
please do not attempt to register for an account with the Services or otherwise
send any Personal Data about yourself to us. If we learn we have collected
personal information from a child under 16, we will delete that information as
quickly as possible. If you believe that a child under 16 years of age has
provided us with Personal Data, please contact us at [email protected].
California
Resident Rights
If
you are a California resident, you have the rights set forth in this section.
Please see the "“Exercising Your
Rights"” section below
for instructions regarding how to exercise these rights.
If
there are any conflicts between this section and any other provision of this
Privacy Policy and you are a California resident, the portion that is more
protective of Personal Data shall control to the extent of such conflict. If
you have any questions about this section or whether any of the following
rights apply to you, please contact us at [email protected].
Access
You
have the right to request certain information about our collection and use of
your Personal Data over the past 12 months. In response, we will provide you
with the following information:
·
The categories of Personal Data that we have collected about
you.
·
The categories of sources from which that Personal Data was
collected.
·
The business or commercial purpose for collecting or selling
your Personal Data.
·
The categories of third parties with whom we have shared
your Personal Data.
·
The specific pieces of Personal Data that we have collected
about you.
If
we have disclosed your Personal Data to any third parties for a business
purpose over the past 12 months, we will identify the categories of Personal
Data shared with each category of third party
recipient. If we have sold your Personal Data over the past 12 months, we will
identify the categories of Personal Data sold to each category of third party recipient.
Deletion
You
have the right to request that we delete the Personal Data that we have
collected about you. Under the CCPA, this right is subject to certain
exceptions: for example, we may need to retain your Personal Data to provide
you with the Services or complete a transaction or other action you have
requested. If your deletion request is subject to one of these exceptions, we
may deny your deletion request. When you submit a deletion request, we will
delete your personal information as soon as possible. If you have any
questions, you can contact us by email [email protected].
Exercising
Your Rights
To
exercise the rights described above, you or your Authorized Agent (defined
below) must send us a request that (1) provides sufficient information to allow
us to verify that you are the person about whom we have collected Personal
Data, and (2) describes your request in sufficient detail to allow us to
understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a "“Valid Request."” We may not
respond to requests that do not meet these criteria. We will only use Personal
Data provided in a Valid Request to verify your identity and complete your
request. You do not need an account to submit a Valid Request.
We
will work to respond to your Valid Request within 45 days of receipt. We will
not charge you a fee for making a Valid Request unless your Valid Request(s) is
excessive, repetitive or manifestly unfounded. If we determine that your Valid
Request warrants a fee, we will notify you of the fee and explain that decision
before completing your request.
You
may submit a Valid Request at [email protected].
You
may also authorize an agent (an "“Authorized
Agent"”) to exercise
your rights on your behalf. To do this, you must provide your Authorized Agent
with written permission to exercise your rights on your behalf, and we may
request a copy of this written permission from your Authorized Agent when they
make a request on your behalf.
Personal
Data Sales Opt-Out and Opt-In
We
will not sell your Personal Data, and have not done
so. To our knowledge, we do not sell the Personal Data of minors under 16 years
of age.
We
Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We
will not discriminate against you for exercising your rights under the CCPA. We
will not deny you our goods or services, charge you different prices or rates,
or provide you a lower quality of goods and services if you exercise your
rights under the CCPA. However, we may offer different tiers of our Services as
allowed by applicable data privacy laws (including the CCPA) with varying
prices, rates or levels of quality of the goods or services you receive related
to the value of Personal Data that we receive from you.
Other
State Law Privacy Rights
California
Resident Rights
Under
California Civil Code Sections 1798.83-1798.84, California residents are
entitled to contact us to prevent disclosure of Personal Data to third parties
for such third parties’ direct marketing purposes; in order
to submit such a request, please contact us at [email protected].
Nevada
Resident Rights
If
you are a resident of Nevada, you have the right to opt-out of the sale of
certain Personal Data to third parties who intend to license or sell that
Personal Data. We do not sell your Personal Data. If you have any questions,
please contact us at [email protected] with the subject line "“Nevada Do Not
Sell Request"”.
Changes
to this Privacy Policy
We’re
constantly trying to improve our Services, so we may need to change this
Privacy Policy from time to time, but we will alert you to any such changes by
placing a notice on the FlowGPT application, by
sending you an email and/or by some other means. Please note that if you’ve
opted not to receive legal notice emails from us (or you haven’t provided us
with your email address), those legal notices will still govern your use of the
Services, and you are still responsible for reading and understanding them. If
you use the Services after any changes to the Privacy Policy have been posted,
that means you agree to all of the changes. Use of
information we collect is subject to the Privacy Policy in effect at the time
such information is collected.
Contact
Information
If
you have questions or complaints about this Privacy Policy or our practices,
please contact us by email at [email protected].