1. INTRODUCTION AND SCOPE
1.1 Overview
Flurzi ("we," "us," "our," or the "Company") operates the Flurzi advertising rewards platform accessible at https://flurzi.com/ and through associated mobile applications (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, store, and protect information about you when you access or use our Platform, whether as a Team Owner creating and managing teams or as a Team Member participating through team codes. We are committed to protecting your privacy and handling your personal information with transparency, security, and in compliance with applicable data protection laws.
1.2 Scope of Application
This Privacy Policy applies to all information collected through our Platform, including our website, mobile applications, application programming interfaces (APIs), and any related services, sales, marketing, or events. It governs the data practices for all users regardless of their geographic location, though specific regional regulations may provide additional rights as detailed in the relevant sections of this Policy. This Policy does not apply to information collected by third parties, including any websites, services, or applications that may link to or be accessible from our Platform.
1.3 Acceptance and Consent
By accessing or using our Platform, creating an account, or clicking "I Agree" or similar consent mechanisms, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our information practices, you must not access or use our Platform. Your continued use of the Platform following the posting of changes to this Policy will be deemed your acceptance of those changes. For certain types of data processing, we may seek your explicit consent separately from your agreement to this Policy.
1.4 Data Controller Information
Flurzi acts as the data controller for personal information collected through the Platform. We determine the purposes and means of processing personal information as described in this Policy. Our decisions regarding your data are made in accordance with applicable laws and our legitimate business interests, always considering your privacy rights and expectations.
2. INFORMATION WE COLLECT
2.1 Information You Provide Directly
Account Registration Information: When you create an account on our Platform, whether as a Team Owner or Team Member, we collect essential information including your full legal name, email address, username, password (stored in encrypted format), date of birth for age verification, country of residence, preferred language, and for Team Members, the team code used to join. Team Owners additionally provide information necessary for team management and potential payment distribution responsibilities.
Profile Information: Users may voluntarily provide additional profile information to enhance their Platform experience, including profile photographs, biographical information, communication preferences, timezone settings, and social media handles. While this information is optional, providing it may unlock additional features or improve your Platform experience.
Financial Information: To facilitate payments and withdrawals, we collect necessary financial information including bank account details for direct deposits, digital wallet addresses, cryptocurrency wallet information where applicable, tax identification numbers as required by law, and billing addresses. This information is collected and processed in accordance with Payment Card Industry Data Security Standards (PCI DSS) and other applicable financial regulations.
2.2 Information Collected Automatically
Device and Browser Information: Our systems automatically collect technical information about the devices and browsers you use to access our Platform, including device type and model, operating system and version, unique device identifiers, mobile network information, browser type and version, screen resolution and display settings, language preferences, and time zone settings. This information helps us optimize the Platform for different devices and troubleshoot technical issues.
Usage and Analytics Data: We automatically collect detailed information about your interactions with our Platform to understand user behavior and improve our services. This includes pages viewed and features accessed, time spent on specific pages or features, click patterns and navigation paths, advertisement viewing history and engagement metrics, search queries within the Platform, error logs and crash reports, performance metrics and loading times, and interaction patterns with Platform elements.
2.3 Information from Third-Party Sources
Social Media Platforms: If you choose to connect your social media accounts, we may receive profile information, friend or contact lists (with appropriate permissions), activity and engagement data, and authentication tokens. You can control what information we receive through your social media privacy settings.
Payment Processors: Our payment partners provide transaction confirmations, payment status updates, fraud detection signals, and compliance-related information. We do not receive or store complete payment card numbers or sensitive authentication data.
2.4 Information About Children
Our Platform is not intended for users under eighteen years of age. We do not knowingly collect personal information from children under eighteen. If we discover that we have inadvertently collected information from a child under eighteen, we will promptly delete such information and terminate the associated account. Parents or guardians who believe we may have collected information from their child should contact us immediately.
3. HOW WE USE YOUR INFORMATION
3.1 Platform Operations and Service Delivery
Account Management: We use your information to create and maintain your account, authenticate your identity during login, manage your preferences and settings, facilitate password resets and account recovery, maintain accurate user records, and provide customer support services. This processing is necessary for the performance of our contract with you.
Service Functionality: Your information enables us to provide core Platform features including displaying relevant advertisements, calculating and tracking earnings, processing withdrawal requests, managing team structures and relationships, enabling communication features, and personalizing your Platform experience based on your preferences and behavior.
3.2 Safety, Security, and Compliance
Fraud Prevention: We analyze user information to detect and prevent fraudulent activity including automated bot detection, multiple account detection, abnormal viewing pattern identification, payment fraud prevention, and account takeover protection. This processing is based on our legitimate interest in maintaining Platform integrity.
Legal Compliance: We process personal information as necessary to comply with applicable laws including anti-money laundering regulations, tax reporting requirements, court orders and legal processes, law enforcement requests (subject to legal review), and regulatory investigations. This processing is necessary for compliance with legal obligations.
4. HOW WE SHARE YOUR INFORMATION
4.1 Within Team Structures
Team Owner Access: Team Owners can access certain information about their Team Members including usernames and profile information, earning statistics and performance metrics, activity levels and engagement data, join dates and status, and aggregated team analytics. Team Owners cannot access Team Members' personal financial information, identity documents, or private communications.
4.2 Service Providers and Partners
Payment Processors: We share necessary information with payment partners to process withdrawals, verify financial accounts, comply with financial regulations, prevent fraud, and resolve disputes. These partners are contractually bound to protect your information and use it only for specified purposes.
Technology Providers: Essential service providers receive limited information including cloud storage providers (encrypted data storage), content delivery networks (performance optimization), analytics platforms (anonymized usage data), email service providers (communication delivery), and security service providers (threat detection).
4.3 Legal and Regulatory Disclosures
Legal Requirements: We may disclose your information when required by subpoenas or court orders, government investigations, regulatory inquiries, national security requests, or other legal processes, always subject to appropriate legal review and user notification where permitted.
5. DATA RETENTION AND DELETION
5.1 Retention Periods
Active Account Data: We retain your personal information for as long as your account remains active and you continue to use our Platform. Active account data includes current profile information, transaction history, earning records, team relationships, and platform activity logs.
Post-Termination Retention: After account termination, we retain certain information for limited periods including financial records (seven years for tax and regulatory compliance), security logs (two years for fraud prevention), legal hold data (as required by litigation or investigation), aggregated analytics (indefinitely in anonymized form), and backup archives (ninety days for disaster recovery).
5.2 Deletion Processes
User-Initiated Deletion: You can delete certain information through your account settings including profile information, communication preferences, linked social accounts, and stored payment methods. Some information cannot be immediately deleted due to legal requirements or legitimate business needs.
6. DATA SECURITY
6.1 Technical Security Measures
Encryption: We implement comprehensive encryption including AES-256 encryption for data at rest, TLS 1.3 for data in transit, encrypted database connections, secure key management systems, and end-to-end encryption for sensitive communications. Payment information receives additional encryption layers compliant with PCI DSS standards.
Access Controls: Platform security includes multi-factor authentication requirements, role-based access permissions, privileged access management, regular access reviews and audits, automated de-provisioning, IP whitelisting for administrative access, and comprehensive activity logging.
6.2 Organizational Security
Personnel Security: All personnel with data access undergo background checks, confidentiality agreements, security training programs, regular security awareness updates, and immediate access revocation upon termination. Access to personal information is limited to personnel with legitimate business needs.
7. ORDER CANCELLATION AND RETURNS POLICY
7.1 Order Cancellation
Cancellation Rights: We reserve the right to cancel orders provided the order hasn't been confirmed. Once an order is confirmed, users cannot cancel it as they will have to wait to receive the item before initiating a return. This policy ensures fair processing and prevents abuse of the ordering system.
7.2 Returns Process
Return Initiation: Returns can only be initiated after receiving the ordered item. Users must contact support within the specified return window to begin the return process. All returns are subject to inspection and approval by our team.
8. YOUR RIGHTS AND CHOICES
8.1 Access Rights
Information Access: You have the right to access your personal information through self-service account dashboards, downloadable reports, API access (for technical users), and formal access requests. We provide information about data categories collected, processing purposes, sharing recipients, retention periods, and your privacy rights.
7.2 Correction Rights
Data Accuracy: You can correct or update your personal information through account settings, profile management tools, support requests, and formal correction requests. We maintain audit logs of significant changes for security and compliance purposes.
7.3 Deletion Rights
Right to Erasure: Subject to legal requirements and legitimate interests, you can request deletion of your personal information. Deletion requests are processed according to our retention policies and legal obligations.
8. INTERNATIONAL DATA TRANSFERS
8.1 Cross-Border Transfers
Global Operations: As a global platform, we transfer personal information across international borders to provide our services. Your information may be processed in countries with different privacy laws than your residence country.
Transfer Mechanisms: We ensure appropriate safeguards for international transfers through Standard Contractual Clauses, adequacy decisions, binding corporate rules, explicit consent where required, and derogations for specific situations.
9. SPECIFIC REGIONAL PROVISIONS
9.1 European Economic Area (EEA) and United Kingdom
Legal Bases: We process EEA and UK personal data based on contract performance (service delivery), legal obligations (regulatory compliance), legitimate interests (fraud prevention, security), consent (marketing, cookies), vital interests (emergency situations), and public interest (rare circumstances).
Additional Rights: EEA and UK residents have enhanced rights including data portability, automated decision-making restrictions, supervisory authority complaints, representative appointments, and compensation claims. Contact information for supervisory authorities is available upon request.
9.2 California (CCPA/CPRA)
California Rights: California residents have specific rights including information disclosure, deletion requests, opt-out of selling/sharing, correction rights, limitation of sensitive data use, and non-discrimination guarantees.
10. COOKIES AND TRACKING TECHNOLOGIES
10.1 Cookie Categories
Essential Cookies: Required for basic Platform functionality including session management, authentication tokens, security features, and load balancing.
Performance Cookies: Help us understand Platform performance through page load metrics, error tracking, feature usage analytics, server response times, and user journey mapping. These cookies are generally first-party and have limited lifespans.
Functionality Cookies: Enhance user experience by remembering personalization choices, recently viewed content, form autofill data, video player settings, and accessibility preferences. Users can disable these with reduced functionality.
Advertising Cookies: Support our advertising ecosystem through view tracking, fraud detection, frequency capping, conversion tracking, and retargeting. These include both first-party and third-party cookies with various retention periods.
11. THIRD-PARTY SERVICES AND INTEGRATIONS
11.1 Third-Party Services
Payment Processors: We integrate with payment providers including Stripe, PayPal, bank transfer services, cryptocurrency platforms, and regional payment methods. Each processor has independent privacy policies governing their data practices.
Analytics Providers: Third-party analytics services include Google Analytics, Mixpanel, Amplitude, Hotjar, and custom analytics platforms. We configure these services to minimize data collection and respect user preferences.
12. DATA PROTECTION FOR SPECIFIC FEATURES
12.1 Team Features
Team Owner Data: Team Owners access aggregated team performance data with individual member details limited to necessary management functions. Personal financial information remains private.
12.2 Advertisement Viewing
Advertiser Data Separation: Individual viewing data is separated from personal identity when reporting to advertisers. Only aggregated, anonymized metrics are shared with advertising partners.
13. PRIVACY POLICY CHANGES
13.1 Notification of Changes
Material Changes: We notify users of material privacy practice changes through email notifications, Platform announcements, app notifications, and prominent website notices. Material changes include new data categories, purpose expansions, sharing practices, and rights modifications.
13.2 Consent for Changes
Affirmative Consent: Certain changes require affirmative consent including new processing purposes, sensitive data collection, expanded third-party sharing, and reduced privacy protections.
14. CONTACT INFORMATION AND COMPLAINTS
14.1 Privacy Contacts
Privacy Team: For privacy inquiries, rights requests, or concerns, contact our dedicated privacy team at:
Email: privacy@flurzi.com
Response Time: Within 30 days
Data Protection Officer: For EEA/UK privacy matters:
Email: dpo@flurzi.com
Response Time: Within 30 days
General Support: For general inquiries and support:
Email: hello@flurziimobileapp.co.uk
Response Time: Within 48 hours
14.2 Complaint Process
Internal Resolution: We encourage users to contact us directly with privacy concerns. Our process includes acknowledging receipt within 48 hours, investigating concerns thoroughly, providing detailed responses, implementing corrective actions, and following up on resolution satisfaction.
15. ADDITIONAL PROVISIONS
15.1 Legal Basis for Processing
Contractual Necessity: We process data necessary for Platform access, service delivery, account management, payment processing, and user support based on our contractual relationship.
15.2 Automated Decision-Making
Automated Processes: We use automated systems for fraud detection, earning calculations, content recommendations, and risk assessments. These systems include human review for significant decisions.
15.3 Privacy by Design
Design Principles: Privacy is embedded in Platform development through data minimization, purpose limitation, privacy-default settings, end-to-end security, user control emphasis, privacy impact assessments, and continuous improvement.
16. CONCLUSION
This Privacy Policy represents our commitment to protecting your privacy while providing valuable services through the Flurzi Platform. We continuously evaluate and improve our privacy practices to maintain your trust and comply with evolving regulations.
Your privacy matters to us. We encourage you to review this Policy regularly, exercise your privacy rights, and contact us with any questions or concerns. Together, we can maintain a Platform that respects privacy while delivering innovative advertising reward services.
Thank you for trusting Flurzi with your information. We take this responsibility seriously and strive to earn your continued confidence through transparent, ethical, and secure data practices.
Last Review Date: September 18, 2025
Next Scheduled Review: March 18, 2026
Policy Version: 1.0.0