Privacy Policy

1. Introduction

Welcome to Flynnstone Flip ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our ad monetization platform for ChatGPT applications.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, company name, and contact details when you sign up for our waitlist or create an account.
• Application Information: Details about your ChatGPT app, including app name, description, and expected daily queries.
• Payment Information: Bank account details or payment processor information for revenue distribution (processed securely through third-party payment processors).

2.2 Automatically Collected Information

• Usage Data: Information about how you interact with our platform, including API calls, ad impressions, click-through rates, and revenue metrics.
• Device Information: IP address, browser type, operating system, and device identifiers.
• Analytics Data: Performance metrics, error logs, and diagnostic information to improve our services.

2.3 FlipID Data (Optional)

If you enable FlipID for enhanced ad targeting:

• Hashed Email Addresses: SHA-256 hashed email addresses of end-users who consent to FlipID (we never store plain-text emails).
• Behavioral Data: Aggregated and anonymized interaction patterns across participating apps for contextual ad targeting.
• User Consent Records: Timestamps and consent preferences for GDPR/CCPA compliance.

3. How We Use Your Information

• Service Delivery: To provide ad serving, revenue tracking, and platform analytics.
• Account Management: To manage your publisher account, process payments, and provide customer support.
• Platform Improvement: To analyze usage patterns, optimize ad performance, and develop new features.
• Communication: To send service updates, revenue reports, and important policy changes (you can opt out of marketing emails).
• Compliance: To comply with legal obligations, enforce our Terms of Service, and protect against fraud or abuse.

4. Data Sharing and Disclosure

4.1 With Advertisers

We share aggregated, non-personally identifiable information with advertisers for campaign performance reporting. Individual user data is never shared without explicit consent.

4.2 With Service Providers

We work with trusted third-party providers for:

• Payment processing (Stripe, PayPal)
• Cloud hosting (Google Cloud Platform)
• Analytics (Google Analytics, self-hosted analytics)
• Email communications (SendGrid, AWS SES)

These providers are contractually obligated to protect your data and use it only for authorized purposes.

4.3 With Demand Partners

We integrate with ad exchanges (Magnite, Google Ad Manager, Amazon Publisher Services) using OpenRTB 2.6 protocol. Only necessary bid request data is shared, and all data sharing complies with IAB standards.

4.4 Legal Requirements

We may disclose information if required by law, court order, or government request, or to protect the rights, property, or safety of Flynnstone Flip, our users, or others.

5. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: All data transmitted to/from our platform uses TLS 1.3 encryption.
• Access Controls: Role-based access controls and multi-factor authentication for internal systems.
• Data Minimization: We collect only the data necessary to provide our services.
• Regular Audits: Third-party security audits and penetration testing to identify vulnerabilities.
• Incident Response: Documented procedures for detecting, responding to, and reporting security incidents.

6. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations:

• Account Data: Retained while your account is active and for 7 years after closure for tax/legal compliance.
• Transaction Data: Revenue and payment records retained for 7 years as required by tax laws.
• Analytics Data: Aggregated analytics retained indefinitely; individual event data deleted after 90 days.
• FlipID Data: Hashed identifiers and behavioral data retained for 13 months (IAB standard).

7. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information (subject to legal retention requirements).
• Portability: Request transfer of your data to another service provider in a machine-readable format.
• Objection: Object to processing of your data for direct marketing or legitimate interests.
• Restriction: Request restriction of processing under certain circumstances.
• Withdrawal of Consent: Withdraw consent for data processing that requires consent (e.g., FlipID).

To exercise your rights, contact us at privacy@flynnstone.ai. We will respond within 30 days.

8. GDPR Compliance (EU Users)

For users in the European Economic Area (EEA), we comply with GDPR requirements:

• Legal Basis: We process data based on contract performance, legitimate interests, or explicit consent.
• Data Protection Officer: Contact our DPO at dpo@flynnstone.ai
• Data Transfers: International data transfers use Standard Contractual Clauses approved by the European Commission.
• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority.

9. CCPA Compliance (California Users)

For California residents, we provide additional rights under CCPA:

• Do Not Sell: We do not sell personal information to third parties.
• Disclosure: Request disclosure of data categories collected, sources, purposes, and third-party sharing.
• Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

California users can submit requests via privacy@flynnstone.ai or call 1-800-FLYNNSTONE.

10. Cookies and Tracking

We use cookies and similar tracking technologies for:

• Essential Cookies: Required for authentication and platform functionality.
• Analytics Cookies: To understand how users interact with our platform (Google Analytics).
• Performance Cookies: To optimize ad delivery and measure campaign effectiveness.

You can manage cookie preferences in your browser settings. Disabling cookies may limit platform functionality.

11. Children's Privacy

Flynnstone Flip is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that a child has provided personal information, we will delete it immediately.

12. International Data Transfers

Our servers are located in the United States and the European Union. By using our platform, you consent to the transfer of your information to these jurisdictions. We use appropriate safeguards (Standard Contractual Clauses, Privacy Shield successor frameworks) for international transfers.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes via:

• Email notification to your registered email address
• Prominent notice on our website and platform dashboard
• In-app notification for significant changes

Continued use of our services after notice of changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices: