Privacy policy
Effective Date: March 27, 2019

We, Fleep Technologies OÜ a private limited company registered in the Republic of Estonia under registration number 12373841 (hereinafter referred also as „Fleep“, „us“, „we“), registered address Akadeemia tee 21/4, Tallinn, Estonia, are committed to safeguarding the privacy of our users.

This policy sets out how we will treat your personal information when using the Fleep messenger service (referred to as the “Service”) as provided via Fleep.io website or our software applications.

By using the Service and agreeing to this policy, you agree to the collection and use of information in accordance with this Privacy Policy. 

WHAT INFORMATION WE COLLECT

Information you provide us

When registering a user account and/or using our Service we will collect certain personal information that you will provide directly to us. The information you provide us may include:

Information we collect from other sources

If you register the Fleep account with your Google, Microsoft or other third party account, we may obtain your contact and profile information, such as your name, e-mail address, profile picture and telephone number, from the pertinent service provider in order to register your Fleep user account.

If you allow, we may access and import your contacts from your phonebook or from your Google or Microsoft account and store the copy of them in the Service so you can access it for creating conversations and add new members to existing conversations.

If you allow, we may access and import your emails together with attached files from your email mailbox provided by Google or Microsoft or by other email providers and store the copy of them in the Service to map them into your conversations as messages.

Information we collect automatically

When you use the Service, we automatically collect the following information:

HOW WE USE YOUR PERSONAL INFORMATION

The following personal information is collected and processed for fulfilment of our legal contract, i.e. in order to provide you the Service:

The following personal information is collected and processed based on your consent:

In addition to the above, we may process your personal data to prevent or act upon potentially prohibited or illegal activities carried out via the Service or in order to comply with obligations arising from the applicable law.

USER CONTENT

The Service enables you to share information with other persons with whom you engage in a conversation. All messages and files are stored and transmitted in an encrypted form. However, please be aware that when you voluntarily disclose your personal information via the Service, your personal information may be collected, used or disclosed by the recipients of the information. Among else, the information you provided may be used to cause direct or indirect damages or harm, for example in the form of identity theft, credit card scam, etc. Please continuously assess the risks you may face when providing sensitive information to third parties via the Service.

You may delete your copy of the messages and files at any time via the Service. Additionally, upon deletion of your account, your access to the content in the Service will terminate. Should you wish to retain the content, please export your conversation history and files prior to deleting your Fleep account.

Please note that your communication with other users via the Service shall remain accessible to them as long as they choose not to delete their user account or the specific content. The messages and files in a conversation will be deleted from the Service within 14 days after all recipients have deleted them or the deleted their Fleep user account.

YOUR RIGHTS AND DATA RETENTION

You may at any time request to see, correct and update the personal information collected about you in course of using the Service via your account settings. You may withdraw your consent for further processing of your personal data by deleting your user account by sending a pertinent request to support@fleep.io.

You may, at any time, request to receive the personal information you have provided to us in course of using the Service in a structured, commonly used and machine-readable format and have the right to transmit the data to another service provider by exporting your conversation history from your account settings.

We will retain your personal information only as long as you have an user account with Fleep. Certain data may be kept beyond the end of your relationship with us, but only to the extent as is reasonably necessary for us to have sufficient information to respond to or act upon any legal issues that may arise after the end of your relationship with us or for as long as required by law. When your personal information is no longer required, we will destroy, delete or convert it into an anonymous form.

DISCLOSURE OF YOUR INFORMATION

We do not sell, trade or otherwise transfer your personal data to any third parties for commercial purposes or otherwise.

We may disclose personal information that we have collected to the legitimate recipient when: (a) required by law; (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; (c) trying to enforce the applicable terms of service or other agreements; (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so.

Fleep may use third party authorized processors such as technical service providers, payment processors and hosting providers to process your data in order to provide you the Services. For example, your data is stored in servers hosted by Amazon Web Services, located in the territory of European Union. Such data processors shall act based on our instructions and in compliance with the standards of this Privacy Policy, the applicable data protection regulations and any other applicable confidentiality and security requirements. Please contact Fleep to receive an updated list of such authorized processors.

FLEEP FOR BUSINESS

Fleep for Business is a messenger service subscription that allows organizations to create and administer Fleep accounts and conversations for facilitating communication related to the organization’s business.

The accounts (“Premium accounts”) and conversations (“Premium conversations”) created under Fleep for Business or transferred to the Fleep for Business are fully owned by the organization and its administrators have full administrative control over them. Among else the organization administrators will be able to access all Premium conversations, remove messages, files and users from such conversations. Organization administrators can access Premium conversations content only by being a member of the conversation or adding themselves to the conversation. Organization administrators can delete and deactivate Premium accounts or reset the account password. It is advisable to consider these implications while using Premium accounts and Premium conversations for your personal communication.

COOKIES

Like most online services, the Service is using cookies. Cookies are small text files placed on the browser or hard drive of your computer, mobile, or other device when you visit a website. Cookies are widely used when providing online services and help to make websites work or work more efficiently as well as to provide information to the website owners. Cookies do lots of different things, for example, remembering user preferences, letting users navigate between pages efficiently and generally improving the user experience. Cookies are not used to personally identify you in any way, nor will they damage your system or files.

We use both "session" cookies and "persistent" cookies in the Service. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We will use the session cookies to: keep track of you whilst you navigate the Service and prevent fraud and increase Service security. We will use the persistent cookies to: enable our Service to recognise you when you visit and keep track of your preferences in relation to your use of our Service

We use Google Analytics and Mixpanel to analyse the use of the Service. Google Analytics and Mixpanel generate statistical and other information about Service use by means of cookies, which are stored on users' computers. The information generated relating to our Service is used to create reports about the use of the Service. The information generated is stored by Google and Mixpanel.

PROTECTION OF PERSONAL INFORMATION

We endeavour to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of your personal information.

We further protect personal information by restricting its access to those employees, contractors, advisers, affiliates and service providers that we determine to reasonably require access to such information for any of the purposes stated in this Privacy Policy.

All electronic transactions entered into via the Service will be protected by encryption technology.

You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to the Service).

You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any information you share with us, however we cannot guarantee its absolute security.

THIRD PARTY WEBSITES AND SERVICES

The Service may provide you access to websites or services owned and operated by third parties. These third party websites and services may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any third party websites or services. Third party websites and services may collect, use and disclose personal information differently than us, so we encourage you to carefully read and review the privacy policy for each third-party website and service that you access from the Service.

DIRECT MARKETING

We may send you Fleep newsletters and e-mails for marketing purposes only if you explicitly consent to such processing by subscribing to the Fleep mailing list. In case you wish to stop receiving e-mails for marketing purposes, please click unsubscribe button, which can be found at the end of such e-mails or change your preference in your account settings.

If you subscribe to the Fleep mailing list for receiving Fleep newsletter and marketing proposals, you acknowledge that Fleep uses services of MailChimp (The Rocket Science Group LLC, based in United States) for managing the e-mail flow, as a result of which your e-mail address may be stored in servers located in United States.

INFRINGEMENT OF PRIVACY

If you have any questions related to this policy or in case of any suspected infringement of your privacy, please contact us at support@fleep.io. The supervisory authority regards to our data processing activities is the Estonian Data Protection Inspectorate (www.aki.ee) which can be contacted by email at info@aki.ee.

OUR DETAILS

The full name of our company is Fleep Technologies OÜ.
Our registered address is Akadeemia tee 21/4, Tallinn, Estonia
You can contact us by email to hello@fleep.io.

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