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PRIVACY POLICY

Effective Date: May 21, 2025 Last Updated: May 21, 2025

This Privacy Policy describes how LOYALTY TOOL Sp. z o.o. ("we", "us", or "our") collects, uses, and protects your personal data in connection with your use of Flavapp (https://flavapp.com).

1. Data Controller

LOYALTY TOOL Sp. z o.o.

ul. Grzybowska 80/82, 00-844 Warsaw, Poland

NIP: 5252811290

REGON: 385242331

KRS: 0000821457

Email: [email protected]

2. Data We Collect

We collect only the data necessary to provide and improve our services:

  • Phone number – used for login and user authentication
  • Email address – used for communication and customer support
  • Uploaded images – processed by AI to generate enhanced versions
  • Billing data – processed through Stripe for payment purposes
  • Technical data – IP address, device type, browser, and cookies

3. Purpose and Legal Basis

We process your data to:

  • Deliver services, including login and payment confirmation (Art. 6(1)(b) GDPR)
  • Fulfill legal obligations, including accounting and tax (Art. 6(1)(c) GDPR)
  • Analyze traffic, secure the app, and improve user experience (Art. 6(1)(f) GDPR)

We do not engage in automated decision-making or profiling beyond AI-based image processing.

4. Data Sharing and Transfers

Your data may be shared with:

  • Stripe, Inc. – for secure payment processing
  • Cloud/hosting providers – for technical infrastructure
  • AI providers – such as OpenAI or Stability AI, for image processing

When transferring data outside the EEA, we use Standard Contractual Clauses (SCCs) or equivalent safeguards.

5. Your Rights

You have the right to:

  • Access, rectify or delete your data
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time

To exercise your rights, contact us at: [email protected]

6. Cookies and Tracking Technologies

We use cookies and tracking tools:

  • Essential cookies – required for the platform to work
  • Analytics cookies (Google Analytics 4) – to understand how users interact
  • Marketing cookies (Meta Pixel) – to provide personalized ads and track campaign performance

These cookies are only activated after you give consent through our cookie banner.

We use a Consent Management Platform (CMP) to manage your preferences, fully compliant with GDPR and the ePrivacy Directive. You can update your preferences anytime via the "Cookie Settings" link in the website footer.

7. Data Security

We implement SSL encryption, access control, and monitoring to protect your personal data against loss, misuse, or unauthorized access.