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FLATCH PRIVACY POLICY
Flicked LLC (“Flatch,” “we,” “us,” or “our”)
Effective Date: July 10, 2026 | Last Updated: July 10, 2026
This Privacy Policy describes how Flicked LLC collects, uses, and shares information when you use the Flatch mobile application (the “App”), the Flatch connected sound device (the “Device”), our community features, and our websites (collectively, the “Services”).
By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use the Services.
The Services are intended for users age 13 and older. Certain features of the App, including account creation, sound recording, and community features, are not available to users under 13. See Section 4 (Children’s Privacy) for details.
• Account information. If you create an account, we collect your email address, a display name you choose, and your date of birth (used solely to verify age eligibility — see Section 4). If you sign in with Google or Apple, we receive your name and email address (or Apple’s private relay email if you choose to hide your email) from that provider. We do not receive your Google or Apple password.
• User content — audio. If you record or upload custom sounds, we collect the audio files you create. Audio recordings may contain your voice or the voices of others, which may constitute personal information. Sounds are stored locally on your phone; sounds you choose to upload, back up, or share are transmitted to and stored on our servers.
• Community activity. If you participate in the Flatch community, we collect the content you post, including sound uploads, comments, votes, sound titles and descriptions, and your public profile information.
• Payment information. If you make a purchase through the Services, payment is processed by our payment processor, Stripe, Inc. We do not receive or store your full payment card number. We receive transaction information such as the item purchased, amount, date, billing name, and the last four digits and brand of your card, which we use for order fulfillment, receipts, refunds, and fraud prevention. Purchases of digital content made through the Apple App Store or Google Play are processed by Apple or Google under their own terms and privacy policies.
• Support communications. If you contact us for support, we collect the information you provide in your message, including your contact information and the contents of your communication.
• Usage and diagnostics. We use Google Firebase Analytics to collect information about how you use the App, such as features used, sounds played, session length, and general usage patterns, and Firebase Crashlytics to collect crash reports and performance diagnostics. These services are configured to limit data collection as described in Section 4.
• Device information. We collect device information such as device model, operating system version, app version, language, and randomly generated app-instance identifiers. For users without an account (“guest mode”), analytics are limited to aggregated or de-identified usage data associated with a random app-instance identifier, not your identity.
• Device pairing and telemetry. The App connects to your Flatch Device over Bluetooth. We collect the Device’s serial number, firmware version, battery status, and pairing status in order to operate, update, and troubleshoot the Device. The App requires Bluetooth permissions to function; on some operating systems, Bluetooth scanning permissions are categorized as location permissions. We do not use Bluetooth to determine or track your physical location.
• Location. We do not collect precise geolocation.
We do not knowingly collect personal information from children under 13 (see Section 4). We do not collect contacts, photos (other than an optional profile picture you choose to provide), precise location, or health data. We do not sell your personal information, and we do not use your custom sound recordings to train artificial intelligence models.
We use the information we collect to:
• Provide, operate, and maintain the Services, including pairing with and sending sounds to your Device;
• Create and manage your account and authenticate you;
• Verify age eligibility as required by law;
• Process payments, fulfill orders, and provide receipts and refunds;
• Host, display, and distribute content you choose to share with the community;
• Moderate the community, enforce our Terms of Service, and respond to reports of abusive or infringing content, including through automated moderation tools;
• Verify the integrity of the App and protect the Services against fraud and abuse (including through Firebase App Check);
• Deliver firmware and software updates to your Device and the App, and send push notifications you have enabled;
• Understand how the Services are used so we can improve them, diagnose problems, and fix crashes;
• Communicate with you about the Services, including service announcements and responses to support requests;
• With your consent where required, send you marketing communications, which you may opt out of at any time;
• Comply with legal obligations and protect the rights, safety, and property of our users, the public, and Flicked LLC.
We take children’s privacy seriously, and the App is designed so that no personal information is collected from children under 13.
• Age screening. We ask for your date of birth before you can create an account. If you indicate that you are under 13, you cannot create an account, record or upload sounds, or access community features.
• Guest mode. Without an account, the App can still be used to pair with a Flatch Device and play the built-in sound library. In this mode, the App does not collect personal information from the user; limited technical and diagnostic data may be processed solely to support the App’s internal operations, as permitted by the Children’s Online Privacy Protection Act (COPPA) and its implementing rule.
• No collection from children. Users who indicate they are under 13 are never asked for microphone permission, cannot create recordings, and cannot submit any content or personal information through the App.
If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly. If you are a parent or guardian and believe your child has provided personal information to us, please contact us at info@flik.me and we will investigate and delete such information as required by COPPA.
Parents and guardians may contact us at any time to ask whether we hold information relating to their child, to review it, or to request its deletion.
We do not sell your personal information, and we do not share your personal information with third parties for their own cross-context behavioral advertising. We share information only in the following circumstances:
• With other users, at your direction. Content you post to the community (uploaded sounds, comments, votes, display name, and profile information) is visible to other users of the Services. Please do not include personal information in sound recordings, titles, or comments that you do not want to make public.
• Service providers. We use third-party vendors to operate the Services. These providers process personal information on our behalf under contracts that restrict their use of it. Our current service providers are: Google LLC (Firebase and Google Cloud Platform — cloud hosting, database, file storage, authentication, analytics, crash reporting, push notifications, app-integrity verification via App Check, serverless functions, and AI-based content moderation via Google Vertex AI); Apple Inc. (Sign in with Apple and Apple Push Notification service); and Stripe, Inc. (payment processing). We will update this list if our providers change.
• Legal requirements and safety. We may disclose information if required to do so by law, subpoena, or other legal process, or where we believe disclosure is necessary to protect the rights, property, or safety of Flicked LLC, our users, or the public, including to enforce our Terms of Service and investigate fraud or abuse.
• Business transfers. If Flicked LLC is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will notify you of any change in ownership or in the uses of your personal information described in this Policy.
• Aggregated and de-identified data. We may share aggregated or de-identified information that cannot reasonably be used to identify you, and we commit to maintaining such data in de-identified form and not attempting to re-identify it.
If you sign in with Google or Apple, your use of those services is governed by their privacy policies. We receive only basic profile information (name and email address) needed to create your account. If you use Sign in with Apple and choose to hide your email, we receive a relay address managed by Apple.
The community features may allow you to share content to third-party platforms (for example, sharing a link to a sound). Content shared outside the Services is governed by the receiving platform’s terms and privacy policy.
Sounds and comments you share with the community are public to other users. You are responsible for the content you post. We may review, moderate, remove, or restrict content that violates our Terms of Service or Community Guidelines. Moderation may be performed by automated systems, including AI-based moderation services provided by Google Vertex AI, as well as by human review.
If you believe content on the Services infringes your copyright or contains your personal information without consent, contact us at info@flik.me.
Deleting your account removes your profile and deletes your community content as described in Section 8; content that others have already downloaded, shared, or re-posted may persist outside our control.
We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer retention period is required by law. Our standard retention periods are:
• Account information is retained while your account is active. When you delete your account, your account information and associated personal information are deleted within 30 days, and residual copies are removed from our backup systems within 90 days, except where retention is required for legal, security, or fraud-prevention purposes.
• Uploaded sounds and community content are deleted when you delete them or delete your account, on the same schedule as account information.
• Analytics data is retained for 14 months and then deleted or aggregated. Crash and diagnostic logs are retained for 90 days.
• Payment and transaction records are retained as required for tax, accounting, and fraud-prevention purposes, generally 7 years.
• Support communications are retained for 3 years.
You can delete your account and associated data directly in the App under Settings → Account → Delete Account, or by contacting us at info@flik.me. We honor deletion requests regardless of how they are submitted.
Depending on where you live, you may have some or all of the following rights with respect to your personal information: the right to know what personal information we collect, use, and disclose; the right to access a copy of your personal information in a portable format; the right to correct inaccurate personal information; the right to delete your personal information; and the right to opt out of the sale or sharing of personal information and certain profiling (we do not sell or share personal information as those terms are defined under applicable state law).
Residents of California, Colorado, Connecticut, Texas, Virginia, and other states with comprehensive privacy laws may exercise these rights by contacting us at info@flik.me or through the in-App privacy controls. We will verify your request using information associated with your account and respond within the time required by applicable law. We will not discriminate against you for exercising your privacy rights. You may designate an authorized agent to submit requests on your behalf. If we decline your request, you may appeal our decision by replying to it with the word “appeal,” and we will respond as required by applicable law.
The Services are currently offered in the United States. If you access the Services from the European Economic Area (EEA) or the United Kingdom, or if the EU or UK General Data Protection Regulation (“GDPR”) otherwise applies to our processing of your personal data, the following additional terms apply.
• Controller. Flicked LLC, 8 The Green, Ste B, Dover, DE 19901, USA, is the controller of your personal data.
• Legal bases. We process your personal data on the following legal bases: performance of a contract (providing the App, Device connectivity, accounts, community features, and purchases); our legitimate interests (securing and improving the Services, preventing fraud and abuse, and moderating content), balanced against your rights and freedoms; your consent (marketing communications and any optional features that request it), which you may withdraw at any time; and compliance with legal obligations (including tax, accounting, and child-protection requirements).
• Your rights. In addition to the rights described in Section 9, you have the right to object to processing based on legitimate interests, the right to restrict processing, the right to data portability, and the right not to be subject to solely automated decisions with legal or similarly significant effects. Automated content moderation is subject to human review on request.
• International transfers. Your personal data is transferred to and processed in the United States. Where GDPR applies, we rely on appropriate safeguards for such transfers, including the European Commission’s Standard Contractual Clauses and, where applicable, our service providers’ certifications under the EU–U.S. Data Privacy Framework and the UK Extension.
• Complaints. You have the right to lodge a complaint with your local data protection supervisory authority (in the UK, the Information Commissioner’s Office).
If you access the Services from Australia and the Privacy Act 1988 (Cth) applies to our handling of your personal information, we handle personal information in accordance with the Australian Privacy Principles to the extent they apply. Your personal information is held and processed in the United States, and by using the Services you consent to this overseas disclosure. You may request access to or correction of your personal information, or make a privacy complaint, by contacting us at info@flik.me; if you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).
We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption of data in transit, access controls, and industry-standard cloud infrastructure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and applicable regulators as required by law.
We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by email before the changes take effect, and we will update the “Last Updated” date above. Material changes to how we handle previously collected personal information will be applied prospectively or with your consent where required by law.
If you have questions about this Privacy Policy or our privacy practices, or wish to exercise your privacy rights, contact us at:
Flicked LLC
Attn: Privacy
8 The Green, Ste B
Dover, DE 19901
info@flik.me
